TaxSlaw

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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When A Shareholder Loses Control of Their S Corporation
August 19, 2024 | Louis Vlahos | Business

Not So Happy Law If given their druthers, most transactional corporate attorneys would prefer to spend their day practicing “happy law,” by which they typically mean transactions that involve capital formation, mergers and acquisitions, joint ventures, business restructurings, and other collaborative-type projects in which the parties have clearly delineated goals,…
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Taxing A Foreigner’s Sale of a Partnership Interest – Déjà Vu All Over Again[i]
August 09, 2024 | Louis Vlahos | Business | Federal

Match Made in Heaven There is no denying that many parts of the Code are complex and, in some cases, too obscure for many “laypersons” to comprehend.[ii] Over time, this reality spawned the need for advisers who are both knowledgeable and experienced in the ways of the Code.[iii] Yet, even…
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Swapping Foreign Real Properties On a Tax Deferred Basis
July 25, 2024 | Louis Vlahos | Income Tax | Real Estate

Bon Voyage? Over the last couple of years, several of my friends have become citizens of the country from which their parents emigrated to the U.S.[i] Also during that period, some acquaintances took advantage of the so-called “golden visa” programs still being offered by a handful of European Union members.[ii]…
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Tax Considerations and the Reclassification of Marijuana – We’re Not There Yet
July 17, 2024 | Louis Vlahos | Federal

Help Us Forget Having been swept along for nine days “by the force of the hostile winds on the fishy sea,” Odysseus and his crew came to a strange land. After securing their ships, Odysseus sent some of his “companions ahead, telling them to find out what men . .…
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The Supreme Court’s Non-Opinion On The “Realization” of Income – A Lost Opportunity?
July 10, 2024 | Louis Vlahos | Federal

Almost That Time In less than four months, the citizens of the United States[i] will be electing their next President to a four-year term.[ii] They will also be deciding which of the two major political parties will “control” the Senate, the House, or both, for at least the next two…
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Funding the Buyout of a Deceased Shareholder With Corporate-Owned Life Insurance – Did the Court Decide Connelly Correctly?
June 28, 2024 | Louis Vlahos | Business

Anticipation You may have heard or even read about the U.S. Supreme Court’s recent decision regarding the date of death value[i] of a deceased shareholder’s shares in a closely held corporation that owned a life insurance policy on the decedent’s life, the proceeds of which the corporation used to redeem…
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Trust Beneficiary Engages In Like Kind Exchange Using Trust Property
June 10, 2024 | Louis Vlahos | Estate

Mere Change in Form It is a basic principle of the income tax that the gain or loss realized by a taxpayer from the conversion of property into cash, or from the exchange of property for other property that differs materially in kind from the exchanged property, is treated as realized income or loss. Moreover, the general rule with respect to such realized gain…
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Collecting an Individual’s Unpaid Taxes from Their Controlled Entities
May 29, 2024 | Louis Vlahos | Federal

You Mess With The Bull . . . An anonymous thinker, lost to history, is credited with having said that the unofficial motto of the IRS is, “We have what it takes to take what you have.” In some instances, the truth of the above statement is manifested in what…
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Tax Authorities of the World Unite? Not Quite, But the IRS Joins the Movement to Tax the Rich
May 15, 2024 | Louis Vlahos | Federal

“Let’s make sure if they move, they have nowhere else to go because we’re all taxing them together.”[i] Around the Globe Earlier this year, the OECD observed there has been a significant increase in global wealth inequality over the last two decades. It also acknowledged that “taxation is a key…
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