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Federal Taxation

  • The U.S. Supreme Court Affirms the Eighth Circuit’s Decision in Favor of the Government Concerning the Estate Tax Treatment of Life Insurance Proceeds Used to Fund a Corporate Redemption Obligation

    By:
    Kevin Matz, CPA, JD, LLM
    |
    Aug 1, 2024
    In Connelly v. U.S., 602 U.S. ___ (6/6/2024), the United States Supreme Court affirmed a decision of the Eighth Circuit Court of Appeals in favor of the government concerning the estate tax treatment of life insurance proceeds that are used to fund a corporate redemption obligation under a buy-sell agreement. The specific question presented was whether, in determining the fair market value of the corporate shares, there should be any offset to take into account the redemption obligation to the decedent’s estate under a buy-sell agreement. 

  • Penalties in Modern Tax Practice

    By:
    Melissa Wiley
    |
    Jun 3, 2024

    “In 1955, there were approximately 14 penalty provisions in the Internal Revenue Code. There are now [in 2011] more than ten times that number.”  Internal Revenue Manual (“IRM”) part 20.1.1.1.1.

    Whenever I am asked why it is that I speak so often about penalties, I highlight the above quote from the IRS’s employee handbook. Whereas there were 14 penalty provisions in 1955, approximately 150 were listed by 2011; there are even more now, 13 years later.

  • The YA Global Tax Court Decision: Private Fund Activities Drag Non-U.S. Fund Investors Into the U.S. Tax Net

    By:
    Mark Leeds
    |
    Jun 3, 2024
    For U.S. history aficionados, November 15 is an auspicious day: It was on this day in 1777 that the Continental Congress approved the Articles of Confederation. These articles framed the basic form of government for what was to become the United States. Well, tax folks working with private funds are likely to remember November 15 for another reason as well. 

  • Nothing to Fear but Fear Itself: Planning in the Current Environment

    By:
    Carl Fiore, JD, LLM
    |
    May 1, 2024
    As the calendar turns to 2024, taxpayers and their advisors face an uncertain future.  Given a divided government for at least the next two years, it is not the usual suspect of potential legislation and sweeping tax changes that fuels this uncertainty. Instead, a declining market, the potential for recession looming, and increasing interest rates has left many taxpayers in a general malaise heading into the new year. However, while this overall economic downturn presents at least short-term challenges, it also creates certain wealth planning opportunities.

  • A Practical Discussion with Respect to Internal Revenue Code Section 1031—The "Like Kind" Tax-deferred Exchange, Part 3

    By:
    Raymond L. Liebman, Esq., CPA
    |
    Apr 1, 2024

    This is the final part of a three-part series explaining the basics of the tax-deferred 1031 exchange, the different types available, the mechanics of how they work, and the benefits to be reaped by a client who decides to partake in such an exchange. To view Part 1, please click here. To view Part 2, please click here.

  • Getting Back to Basics: Securities Analysis and Section 475 Elections

    By:
    Brandon Blitzer, CPA and Edward Weissman, CPA
    |
    Apr 1, 2024
    In the dynamic world of financial markets, investors and traders employ various strategies to maximize returns and manage risks. However, these strategies often come with complex (at times, costly) tax implications that can significantly affect the taxable income reported. Understanding the common tax adjustments that arise from trading in the financial markets (e.g., wash sales, straddle adjustments, constructive sales) and the methods to remedy or control the amount of the adjustments are key to a tax-efficient trading strategy.

  • A Practical Discussion with Respect to Internal Revenue Code Section 1031—The "Like Kind" Tax-deferred Exchange, Part 2

    By:
    Raymond L. Liebman, Esq., CPA
    |
    Mar 1, 2024

    This is the second part of a three-part series explaining the basics of the tax-deferred 1031 exchange, the different types available, the mechanics of how they work, and the benefits to be reaped by a client who decides to partake in such an exchange. To view Part 1, please click here.
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