Author Archives: David L. Silverman, J.D., LL.M. (Taxation)

Installment Sales in Real Estate Transactions

An “installment sale” is a disposition of property in which at least one “payment” is to be received after the close of the taxable year in which the disposition occurs. IRC §453(b)(1). The “installment method” is the default method prescribed by the Code to report income from installment transactions unless the taxpayer elects not to use the installment method. This election must be made no later than the due date of the tax return (including extensions) for the taxable year in which the disposition occurs. IRC §453(d)(1). Continue reading

Posted in Federal Income Tax, Installment Reporting | Tagged , , , , , , , | Leave a comment

Executor and Trustee Commissions Under the New York EPTL

For PDF press here: Executor and Trustee Commissions Under the NY EPTL.wpd A. Executor Commissions 1. Statutory Commission Rates In New York, Executor commissions are set out by statute. Surrogate’s Court and Procedure Act (SCPA) § 2307 provides that a … Continue reading

Posted in Executor & Trustee Commissions | Tagged , , , , , | Leave a comment

Peering Through the Legal Prism: When Asset Protection Becomes Fraudulent

VIEW IN PDF:  Tax News & Comment — August 2011 I.  Introduction English law addressing fraudulent conveyances dates back to the early Middle Ages. The first comprehensive attempt to prohibit such transfers appeared in the Fraudulent Conveyances Act of 1571, … Continue reading

Posted in Asset Protection | Tagged , , , , , , , , , , , , , , , , , , , , , , , | Leave a comment

Peering Through the Legal Prism: When Asset Protection Becomes Fraudulent

VIEW IN PDF:  Tax News & Comment — August 2011 I.  Introduction English law addressing fraudulent conveyances dates back to the early Middle Ages. The first comprehensive attempt to prohibit such transfers appeared in the Fraudulent Conveyances Act of 1571, … Continue reading

Posted in Asset Protection | Tagged , , , , , , , , | Leave a comment

August Comment — Deferred Exchanges Under the Regulations

VIEW IN PDF:  Tax News & Comment — August 2011 [Note: Excerpted from Like Kind Exchanges of Real Estate Under IRC. §1031 (David L. Silverman, 3rd Ed.,1/11).View treatise at nytaxattorney.com] I.  Overview of Statute A deferred exchange may be a … Continue reading

Posted in Deferred Exchanges, Like Kind Exchanges | Tagged , , , , , , | Leave a comment

From The Courts — Recent Developments, August 2011

VIEW IN PDF:  Tax News & Comment — August 2011 The Supreme Court, in an unanimous opinion, held that a medical resident whose normal work schedule requires him to perform services 40 or more hours per week, is not a … Continue reading

Posted in From the Courts, Tax Decisions, Tax News & Comment | Tagged , , , , , , | Leave a comment

From The IRS — Recent Developments, August, 2011

VIEW IN PDF:  Tax News & Comment — August 2011 Approximately one million U.S. taxpayers have at least one financial account located in a foreign country. Many have not reported their offshore accounts to the IRS, a violation with possible … Continue reading

Posted in IRS Matters, IRS Rulings & Regulations, Tax Decisions, Tax News & Comment | Tagged , , , , , | Leave a comment

Tax News & Comment — August 2011

VIEW IN PDF:  Tax News & Comment — August 2011 Approximately one million U.S. taxpayers have at least one financial account located in a foreign country. Many have not reported their offshore accounts to the IRS, a violation with possible … Continue reading

Posted in Tax News & Comment | Tagged , , , , , , , , , , , , , , , , , | Leave a comment

Differing Tax Visions of President Obama and Governor Romney

Much has been made of the recent revelation that Governor Romney enjoyed a 14 percent tax rate on “carried interest,” which Congress permits to be reported as capital gain. Investors such as Mr. Romney pay a lower rate of tax … Continue reading

Posted in From Washington, Tax News & Comment | Tagged , , , , , , , , , , , , , , , , , , | Leave a comment

Recent IRS Developments

A.      Recent IRS Developments Field audits of taxpayers with incomes exceeding $200,000 rose 34 percent in fiscal 2011 to 78,392. IRS Deputy Commissioner Steve Miller stated that “[w]e are looking more at taxpayers at these income levels because we … Continue reading

Posted in News, Tax Decisions, Tax News & Comment | Tagged , , , , , , , , , | Leave a comment

Tax News & Comment — April 2011

View Issue: Tax News & Comment — April 2011 pril 14, 2011 I. ESTATE TAX RETURNS Calculation and remittance of federal and NYS estate tax is of primary concern in administering an estate. An estate tax return must be filed … Continue reading

Posted in Tax News & Comment | Tagged , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , | Leave a comment

Post Mortem Estate & Income Tax Planning

View outline: Post Mortem Estate & Income Tax Planning Post Mortem Estate and Income Tax Planning Outline Post Mortem Estate & Income Tax Planning © 2011 David L. Silverman, J.D., LL.M. (Taxation) Law Offices of David L. Silverman 2001 Marcus … Continue reading

Posted in Estate Planning, Post Mortem Estate & Income Tax Planning, Post Mortem Estate & Income Tax Planning, Post Mortem Estate Planning, Probate & Administration, Treatises | Tagged , , , , , , , , , , , , , , , , , , | 1 Comment

New York State Tax Litigation

View Outline:  New York State Tax Litigation view outline:  New York State Tax Litigation New York State Tax Litigation © 2011 David L. Silverman, J.D., LL.M. (Taxation) Law Offices of David L. Silverman 2001 Marcus Avenue, Suite 265A South Lake … Continue reading

Posted in NYS Tax Litigation, Treatises | Tagged , , , , , , , , , | Leave a comment

“Bifurcation” of Personal Injury and Medical Malpractice Trials in New York Unfair

Under current New York trial practice in some courts in the State, personal injury and medical malpractice trials are “bifurcated” into two separate “mini” trials.  This policy is not one of the legislature; rather, it is a judicial policy which … Continue reading

Posted in NYS Commercial Litigation | Tagged | Leave a comment

January 31, 2011 Like Kind Exchange Seminar at HSBC

A seminar for accountants and attorneys sponsored by HSBC bank, with Mr. Silverman as the speaker, will be held at HSBC World Headquarters in Manhattan on January 31, 2011. The topic will be Like Kind Exchanges Under IRC § 1031. … Continue reading

Posted in Seminars | Leave a comment