Paul Graham Op Ed: How People Get Rich Now (April 2020)

Paul Graham, founder of Y Combinator, wrote an op ed on his extensive blog, How People Get Rich Now. The article begins as follows: Every year since 1982, Forbes magazine has published a list of the richest Americans. If we compare the 100 richest people in 1982 to the 100 richest in 2020, we notice some big … Continue reading Paul Graham Op Ed: How People Get Rich Now (April 2020)

IRS Practice Unit Updated: Receipt of Dividends or Interest from a Related CFC (March 29, 2021)

The IRS has updated its practice unit on receipt of dividends or interest from a related controlled foreign corporation. The overview is as follows: Note: This Unit was revised to include the extension of the IRC 954(c)(6) look through rule for CFCs with tax years beginning before January 1, 2026. This extension was part of … Continue reading IRS Practice Unit Updated: Receipt of Dividends or Interest from a Related CFC (March 29, 2021)

IRS Updates Practice Unit on Liquidating Distributions of Partners Interest in Partnership (April 2, 2021)

The IRS has updated its practice unit on liquidating distributions of a partners interest in a partnership. The overview is as follows: All partnership distributions are either current or liquidating. A liquidating distribution terminates a partner’s entire interest in the partnership. A current distribution reduces a partner’s capital accounts and basis in his interest in … Continue reading IRS Updates Practice Unit on Liquidating Distributions of Partners Interest in Partnership (April 2, 2021)

President Biden Announces The Made in America Tax Plan proposing corporate tax changes; the American Families Plan with individual tax changes coming soon (April 1, 2021)

On March 31, 2021, President Biden announced The American Jobs Plan portion of his Build Back Better program, which contains corporate tax changes in The Made in America Tax Plan. He also announced that The American Families Plan, which will propose individual tax changes will be coming soon. See the details at the following links: … Continue reading President Biden Announces The Made in America Tax Plan proposing corporate tax changes; the American Families Plan with individual tax changes coming soon (April 1, 2021)

Senator Bernie Sanders introduces two pieces of legislation: The 99.5% Act and The Corporate Tax Dodging Prevention Act; Practitioners View These as The Vehicles Congress + Biden Admin Will Use for Ultimate EGT and Corporate Tax Increases (Mar. 29, 2021)

On Thursday, March 25, 2021, Senator Bernie Sanders co-sponsored two pieces of legislation, which many view as the vehicles for ultimate tax increases: The the 99.5% Act and The Corporate Tax Dodging Prevention Act. The effective date provision of the 99.% Act with EGT provisions provides that it applies to transfers made after December 31, … Continue reading Senator Bernie Sanders introduces two pieces of legislation: The 99.5% Act and The Corporate Tax Dodging Prevention Act; Practitioners View These as The Vehicles Congress + Biden Admin Will Use for Ultimate EGT and Corporate Tax Increases (Mar. 29, 2021)

Bloomberg: Biden Determined to Tax Rich After Windfalls From Covid Crisis (Mar. 22, 2021)

Bloomberg News is reporting that President Biden is determined to increase taxes on the wealthy, with that determination being reinforced by reported windfalls experienced by the wealthy during the pandemic during the "K-shaped" recovery. The Bloomberg article begins as follows: President Joe Biden’s economic team at the White House is determined to make good on … Continue reading Bloomberg: Biden Determined to Tax Rich After Windfalls From Covid Crisis (Mar. 22, 2021)

Probate Stars: In re Trust Created by McGregor: Nebraska Supreme Court: Nonjudicial Settlement Agreement Violated Material Purpose Of Trust By Ignoring Spendthrift Provision (Feb. 25, 2021)

Probate Stars summarizes n In Re Trust Created By McGregor, in which the Nebraska Supreme Court held that spendthrift provisions of a trust established a material purpose of the trust, and held a nonjudicial settlement agreement invalid for violating the trust’s purpose. See Probate Sources Summary by clicking Nebraska Supreme Court: Nonjudicial Settlement Agreement Violated … Continue reading Probate Stars: In re Trust Created by McGregor: Nebraska Supreme Court: Nonjudicial Settlement Agreement Violated Material Purpose Of Trust By Ignoring Spendthrift Provision (Feb. 25, 2021)

NY Times + Washington Post Op Eds Call for Increased IRS Tax Enforcement, Especially on the Wealthy

Separate Op Ed pieces in the New York Times and The Washington Post call for increased funding to increase IRS tax enforcement, especially on the wealthy. See following articles: Chye-Ching Huang, Executive Director Tax Law Center, NYU School of Law, How Biden Funds His Next Bill: Shrink the $7.5 Trillion Tax Gap (March 10, 2021).Greg … Continue reading NY Times + Washington Post Op Eds Call for Increased IRS Tax Enforcement, Especially on the Wealthy

PLR 202109002 and PLR 202109003 (Mar. 8, 2021): Investment Advisory Fees Not Treated as “Amount Received” for Code Sec. 72(e) Purposes for Annuity Contracts

In PLRs 202109002 and 202109003, the Service ruled that t certain annuity contract investment advisory fees are not treated as amounts received by the contract owner for Code Sec. 72(e) purposes. The taxpayers were insurance companies offering non-qualified deferred annuity contracts. The IRS stated observed that the fees, which were integral to the contracts, did … Continue reading PLR 202109002 and PLR 202109003 (Mar. 8, 2021): Investment Advisory Fees Not Treated as “Amount Received” for Code Sec. 72(e) Purposes for Annuity Contracts

Baker McKenzie Family Office Forum Feb. 24-25, 2021

Baker McKenzie has announced its Virtual Family Office Forum. The agenda is as follows: The 2021 Family Office Forum provides families and family office professionals with engaging presentations and interactive discussion on pressing topics for family offices. Stay ahead of the curve by joining this two-day virtual event from February 24-25, 2021.The full agenda with session descriptions … Continue reading Baker McKenzie Family Office Forum Feb. 24-25, 2021

Forbes: Biden Wants To Limit The Capital Gains Tax Preference. History Shows It Will Be Hard (Feb 16, 2021)

Forbes has published an article, Biden Wants To Limit The Capital Gains Tax Preference. History Shows It Will Be Hard, which discusses [INSERT GENERAL SUBJECT]. The article begins as follows: President Biden wants to revamp the taxation of capital gains, but if history is any guide, it won’t be easy. The tax preference for capital gains turns … Continue reading Forbes: Biden Wants To Limit The Capital Gains Tax Preference. History Shows It Will Be Hard (Feb 16, 2021)

IRS Practice Unit: Qualified Dividends and Capital Gains Rate Differential Adjustments (Jan. 4, 2021)

The IRS has released an updated practice unit on Qualified Dividends and Capital Gains Rate Differential Adjustments. The abstract is as follows: The United States (U.S.) taxes its individual residents and citizens on their worldwide income. To prevent double taxation, U.S. taxpayers are allowed a credit for foreign income taxes “paid or accrued” on income … Continue reading IRS Practice Unit: Qualified Dividends and Capital Gains Rate Differential Adjustments (Jan. 4, 2021)

Washington Post: Inside the IRS: The department is charged with the stimulus and tax season is barely hanging on (Feb. 12, 2021)

The Washington Post reports that, while President Biden's plans rely heavily on teh IRS, the IRS is already struggling due to years of budget cuts among other issues. The article begins as follows: As President Biden charts his coronavirus economic recovery agenda through the Internal Revenue Service, the nation’s tax collector will take on an … Continue reading Washington Post: Inside the IRS: The department is charged with the stimulus and tax season is barely hanging on (Feb. 12, 2021)

Joint Committee on Taxation Releases Several Publications Re Budget Reconciliation Recommendations and More

The Joint Committee on Taxation has released several publications related to Budget Reconciliation recommendations as well as certain other matters. See and download the full Joint Committee publications by the links below: JCX-2-21: JCT Description of the Budget Reconciliation Legislative Recommendations Relating to Continuation of Job-Based Coverage.JCX-3-21: JCT Description of the Budget Reconciliation Legislative Recommendations … Continue reading Joint Committee on Taxation Releases Several Publications Re Budget Reconciliation Recommendations and More

House Ways + Means Chairman Neal Announces Markup of COVID-19 Relief Measures (Feb. 8, 2021).

SPRINGFIELD, MA – Today, House Ways and Means Committee Chairman Richard E. Neal (D-MA) announced the Committee will consider nine legislative proposals under the budget reconciliation instructions this week as the next step in delivering COVID-19 relief to the American people. Beginning on Wednesday, February 10, 2021 at 10:00 a.m. through Friday, February 12, 2021, the … Continue reading House Ways + Means Chairman Neal Announces Markup of COVID-19 Relief Measures (Feb. 8, 2021).

HBR: Josh Baron & Rob Lachenauer, Build a Family Business That Lasts (Feb. 2021)

Josh Baron & Rob Lachenauer have published their Harvard Business Review article, Build a Family Business That Lasts (Feb. 2021). The article begins as follows: Given their portrayals in the media, it might be easy to dismiss family businesses as hotbeds of power playing, favor currying, and back-stabbing—preoccupations that can hurt the company, the family, … Continue reading HBR: Josh Baron & Rob Lachenauer, Build a Family Business That Lasts (Feb. 2021)

BDO: 2020 Year-End Tax Planning For Individuals (October 2020)

BDO has published an article, "2020 Year-End Tax Planning For Individuals," which discusses tax planning for 2020.  The article begins as follows: As the year-end approaches, individuals, business owners and family offices should be reviewing their situations to identify any opportunities for reducing, deferring or accelerating tax obligations. Areas that should be looked at in … Continue reading BDO: 2020 Year-End Tax Planning For Individuals (October 2020)

Sharon L. Klein (Family Matter)- New York’s Latest Legislative Session: What Passed, What Didn’t, What’s Next (September 14, 2020)

Sharon L. Klein, President of Family Matter, has made available for download her article, New York’s Latest Legislative Session: What Passed, What Didn’t, What’s Next, published in the New York Law Journal Special Trusts & Estates section. The abstract is as follows: Learn about what passed and what didn’t in New York’s 2019- 2020 legislative session … Continue reading Sharon L. Klein (Family Matter)- New York’s Latest Legislative Session: What Passed, What Didn’t, What’s Next (September 14, 2020)

TaxProf Blog – Bryan Camp: Lesson From The Tax Court: Receipts Are Not Enough (September 21, 2020)

Bryan Camp has published an article on the TaxProf Blog, titled Lesson From The Tax Court: Receipts Are Not Enough. The article begins as follows: In Anna M. Armstrong v. Commissioner, T.C. Sum. Op. 2020-26 (Sept. 17, 2020), Judge Panuthos teaches that substantiation does not just mean showing the amount of an expense; it means showing entitlement to deduct that expense.  … Continue reading TaxProf Blog – Bryan Camp: Lesson From The Tax Court: Receipts Are Not Enough (September 21, 2020)

Forbes: IRS Taxes Most Lawsuit Settlements And Exact Wording Matters (September 28, 2020)

Forbes has published an article, "IRS Taxes Most Lawsuit Settlements And Exact Wording Matters," which discusses how changes to tax laws have affected tax treatments of legal fees. The article begins as follows: If you collect a legal settlement is it taxable? Usually yes, but the tax treatment varies depending on how you were damaged, how … Continue reading Forbes: IRS Taxes Most Lawsuit Settlements And Exact Wording Matters (September 28, 2020)