Recent Publications - Tax


Employee-Shareholders, Reasonable Compensation And Employment Taxes
July 19, 2021 | Tax
Movement Toward Tax Increases You may have read last week that Democrats on the Senate Budget Committee announced they had reached a deal on a budget resolution that will enable them to bypass Senate Republicans on the way to enacting most of the “social infrastructure” programs called for under the President’s American Families Plan.[i] Significantly, …
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Bona Fide Intercompany Loan – Are you Sure?
July 12, 2021 | Tax
Head-Scratchers The Code is chock-full of provisions that will challenge the intellectual capacity, not to mention the patience, of most tax professionals. The complexity of these rules does not arise out of some sadistic intent on the part of Congress, the Treasury, or the IRS to torment taxpayers and their advisers;[i] rather, it is often …
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Like a Good Neighbor, New York is Still Free to Tax You – Sorry for the Inconvenience
July 6, 2021 | Trusts & Estates | Tax
NH vs MA Last week, the U.S. Supreme Court denied New Hampshire’s request that the Court exercise its original jurisdiction under the Constitution[i] to hear and resolve a conflict involving the taxation by Massachusetts of income earned by certain residents of the Granite State.[ii] The disagreement between the two jurisdictions originated when Massachusetts, in response …
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Tax Increases in Sight? Time to Sell the Business? Focus on Economics
June 28, 2021 | Trusts & Estates | Tax
Not Good As Mr. Biden settled into the White House, and as the Democrats began planning how to best utilize their slim Congressional majority to enact and pay for their sweeping legislative agenda, the principal concern among most owners of successful closely held businesses was Mr. Biden’s proposal to almost double the federal income tax …
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Tax Changes in the Offing? “Close Scrutiny” of Business Owners’ Economic Benefits Remains a Constant
June 21, 2021 | Tax
I Read the News Today Much of today’s news is dominated by the future of the Administration’s broadly defined infrastructure plan. Discussions among “those in the know” inevitably turn into debates over the wisdom of pursuing the bipartisan legislative approach favored by centrists from both sides of the political divide as contrasted with the “go-it-alone …
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Partners, S Corp. Shareholders and Biden’s 2022 Revenue Proposal: No More Business as Usual
June 14, 2021 | Tax
What A Ride No one anticipated that the Administration’s proposed tax increases would fly through Congress easily – at least no one residing in a state in which the recreational use of marijuana has not been legalized. Query, however, whether anyone foresaw the rollercoaster-like developments of the last several days. The G-7 As the White …
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Biden’s 2022 Revenue Proposal, Profits Interests, and The Alchemy of Compensation
June 7, 2021 | Tax
Recap Last week, we considered several of the revenue proposals included in the Biden Administration’s 2022 Budget that are probably of interest – or should we say, “of concern”? – to the owners of closely held businesses.[i] Rate Hikes The proposed increases in the federal corporate income tax rate – for C corporations[ii] and for …
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The Biden Administration’s Revenue Proposals for Fiscal Year 2022: Tax Increases and Forced Recognition of Capital Gains
June 1, 2021 | Tax
Extra, Extra![i] Last Friday afternoon, as millions of unsuspecting Americans prepared for the long Memorial Day weekend[ii] – for many, perhaps, their first mask-less holiday celebration in almost 15 months – the Biden Administration released its 114-page “Green Book” for the federal government’s 2022 fiscal year.[iii] I must confess, I really was looking forward to …
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“Opaque Income Sources” + “Tax Gap” = More Enforcement + Tax Hikes = Anyone’s Guess
May 24, 2021 | Tax
Tax Gap In a report released last week, the U.S. Treasury Department explained that the so-called “tax gap” – i.e., the difference between the amount of federal income taxes owed by taxpayers for a taxable year and the amount actually paid for such year – “disproportionately benefits high earners who accrue more of their income …
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Cash in Hand, Tax Deferral, Monetized Installment Sales: No, You Can’t Have It All
May 17, 2021 | Tax
Dream Until the Dream Come True?[i] Ask the owner of a closely held business to describe their most recently recurring nightmare and you are likely to get an earful regarding the prospect of an increased federal income tax on their profits, an increased federal tax on the long-term capital gain from the sale of their …
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