TaxSlaw

Expiring Federal Transfer Tax Benefits – Nothing is Certain or Lasts Forever
January 13, 2025 | Louis Vlahos | Federal

Expiring Provisions Just a few weeks ago, many individual taxpayers, driven by what they viewed as the relatively imminent expiration of the enhanced federal transfer tax[i] exemptions, sought advice on how to leverage their remaining exemption and thereby optimize the transfer of value to their beneficiaries while limiting the amount…
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The Status of the Corporate Transparency Act – It’s Not Clear
January 02, 2025 | Louis Vlahos | Federal

Legitimate Interest Few would argue that the federal government does not have a legitimate interest in preventing, detecting, and punishing tax fraud, money laundering, and other financial crimes. Likewise, I imagine few would disagree with the precept that the means by which the federal government chooses to perform these functions…
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The Holidays – A Time for Family, Reflection and. . . GST Tax Planning?
December 10, 2024 | Louis Vlahos | Estate

Holiday Gatherings How was your Thanksgiving? I hope you celebrated the holiday in a pleasant setting with folks whose company you enjoyed, and with plenty of good food. I hope you participated in some interesting conversations or joined in some fun games. I hope your NFL team put on a…
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Abandoning N.Y. Domicile – Must the Business Owner Abandon Their N.Y. Business?
November 21, 2024 | Louis Vlahos | Business

Another “Departure” During the weeks leading up to the Presidential election, the media carried stories about wealthy supporters from each Party who had announced their intention to leave the country if the other Party’s candidate became President. Of course, none of these individuals stated they would be giving up their…
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Choice of Entity for a U.S. Business- Passthrough Status Matters Beyond the U.S. Border
November 12, 2024 | Louis Vlahos | Business

Decisions, Decisions The owners of a closely held U.S. business will have to make many difficult decisions during the life of the business. Among the earliest of these is the so-called choice of business entity, the economic (including tax) consequences of which will be felt by the business and its…
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Challenge to Collection Due Process? Will Supreme Court Affirm IRS’s Offset of Valid Refund With Disputed Tax Liability?
October 30, 2024 | Louis Vlahos | Business | Federal

Enforcement Earlier this year the IRS announced that, as part of its larger compliance efforts begun last fall under the Inflation Reduction Act,[i] the agency’s stepped-up enforcement activity with respect to high wealth, high income individuals had generated more than $1 billion in collections of past-due taxes. One would be…
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Thinking About Making Taxable Gifts Before the 2026 Sunset?
October 10, 2024 | Louis Vlahos | Business | Estate | Federal

As we will see shortly, it is often “better to give than to receive,”[i] though this statement begs the obvious question[ii] of whether it is better to do so during one’s lifetime or upon one’s death. Many well-to-do individuals are seriously deliberating this question[iii] as they contemplate the impending federal…
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New York Tax Continues to Inconvenience Nonresidents Working Remotely
September 25, 2024 | Louis Vlahos | New York State

Thus Spoke the Governor Last Friday, New York’s Governor Hochul[i] delivered the following remarks at the annual meeting of the Business Council of New York State:[ii] “Someone asked me today, are we going to raise income taxes? I said, ‘I’m not raising income taxes.’ I said I’m not. I stopped…
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Unconstitutionally Excessive FBAR Penalties? It Depends
September 17, 2024 | Louis Vlahos | Federal

Raking It In You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received third party information[i] indicating these individuals had received income in excess of $400,000 but had…
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New York’s Tax Treatment of Compensatory Restricted Stock and Dividends in the Hands of a Nonresident Executive
September 03, 2024 | Louis Vlahos | Income Tax | New York State

August is Like Sunday As far back as I can remember, the end of August has always elicited a sense of dread comparable to what many schoolchildren, and a fair number of adults, experience every Sunday afternoon. In retrospect, I cannot say that this feeling of doom was ever fully…
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