A divorce often brings to light a multitude of issues — from financial to legal to emotional. While it might not be on the top of your list during the transition, complying with the IRS on your next tax return means understanding how your carryforwards may be split when your joint return...
Read MoreMany employers reward key executives and employees by offering non-qualified deferred compensation plans, which allow them to contribute unlimited amounts of compensation on a tax-deferred basis. This is a significant enticement for upper-tier employees, as they are generally highly compensated...
Read MoreIn which state your trust “lives” — including your grantor, trustee, administration and even perhaps your beneficiary — will determine how the trust will be taxed. Residency status also helps identify what planning opportunities may be available to minimize the tax. ...
Read MoreIf you have a household, or domestic, employee then you may have employment tax obligations to fulfill as an employer. While some household employees may seem obvious, others may not. To stay compliant, it’s important to first understand the definition of each and then which IRS, state...
Read MorePrivate equity fund advisers earn income in different ways, including via management fees and profits interests. Strategic planning techniques — such as opting to waive the management fee — can help an adviser potentially defer income or take advantage of more preferential income...
Read MoreOn October 5, 2016, the IRS issued final, temporary and proposed regulations on partnership disguised sales and allocation of liabilities. Under these regulations (and consistent with the prior regulations), when a partner contributes property to a partnership and receives a distribution within...
Read MoreOver the years we have seen companies, many of whom operate in real estate, purchase debt in the secondary market often significantly below the principal amount owed. The goal is to collect the price paid for the debt as well as a substantial portion of its original principal amount...
Read MoreGenerally, a partner who sells an interest in a partnership will recognize capital gain or capital loss on the disposition. However, Internal Revenue Code Section 751 may cause an unanticipated tax consequence — the need for the partner to recognize ordinary income on the sale of the...
Read MoreIf you’ve invested in a small business and sold the stock after holding it for more than five years, you may be able to exclude a percentage of your gain under Internal Revenue Code (IRC) Section 1202. This federal tax benefit can provide investors with significant tax savings, resulting in...
Read MoreAre you in the auto sales industry? If so, you may be able to exclude the use of a demonstrator (demo) vehicle from gross income and wages — and save on your income and payroll taxes. Generally, full-time auto salespeople using a demo in the area surrounding the sales office can...
Read MoreThe consequences of doing business in a country with which the U.S. has a tax treaty can be much different than those encountered when dealing with a non-treaty country. It’s important to understand the basic differences of each. Treaty CountriesThe United States has a number of...
Read MoreThe kiddie tax was added by the Tax Reform Act of 1986 to help prevent wealthy taxpayers from shifting investment assets to children, who generally enjoy lower tax brackets. In its 30-plus years of existence, the kiddie tax has expanded its reach from dependents under the age of 14 to those under...
Read MoreIt’s imperative that landlords and tenants know the tax ramifications — for better or worse — of the language that’s built into their lease and ancillary agreements. And it’s just as important to be aware of tax-impacting items not found in any written agreement...
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There is yet another dangerous phishing scheme circulating once again this tax season involving W-2s that targets corporations, schools and nonprofits. In a recent IRS communication, IRS Commissioner John Koskinen has said that this particularly dangerous scheme could “result in the large...
Read MoreWhen we talk about a business compensating its service providers — which can include employees, attorneys, brokers and real estate developers, to name a few — it can mean more than just paying wages, bonuses or fees. Many providers want more than a check; they want to share in, and...
Read MoreIf you own property and a business, there’s an obvious temptation to lease that property to the business. But be careful — you risk triggering the self-rental rule and catching the eye of the IRS. One creative couple tried to get around this by using an S corporation to lease their...
Read MoreThe IRS has issued three sets of regulations — final, temporary and proposed — addressing disguised sales of property involving partnerships, the allocation of partnership liabilities and several other issues related to partnerships. The regulations are largely intended to eliminate...
Read MoreTargeted capital allocations are becoming standard in new LLC or partnership operating agreements. Historically, operating agreements typically provided for income/loss allocations to the partners based on the safe harbor provided under IRC Regulation 1.704-1(b)(2). This was more of a “cash...
Read MoreCan my private company benefit from a corporate tax inversion? I’ve been asked this question more frequently over the last few years as corporate tax inversions have gained momentum in the media and attention from politicians. The answer is, while you may be able to undergo a conversion, it...
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