Category Archives: Federal Income Tax

Like Kind Exchanges Alive and Well: An Update Attempts by the Obama administration to curtail or eliminate IRC § 1031 exchanges were decidedly unsuccessful. Based upon their pronouncements, neither Ms. Clinton nor Mr. Trump would be expected to attempt to … Continue reading

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IRS & NYS DTF Matters; Recent Developments & 2014 Regs. & Rulings of Note

I. New York State Matters NYS Amends Estate & Gift Tax Beginning April 1, 2014, the NYS estate exemption will increase every 12 months through 2017. On April 1, 2014, the NYS exemption became $2.0625; on April 1, 2015, $3.125 … Continue reading

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Private Letter Ruling Requests

I. Introduction Private letter rulings are in the nature of “advisory” rulings by the IRS concerning the tax implication of income or estate transactions contemplated by taxpayers. As stated in Rev. Proc. 2015-1, the IRS generally issues a letter ruling … Continue reading

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Avoiding Boot Gain in Like Kind Exchanges

I. Introduction Circular 230 disclosure: Any tax advice herein is not intended or written to be used, and cannot be used by any taxpayer, for the purpose of avoiding any penalties that may be imposed under the Internal Revenue Code. … Continue reading

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From Washington & Albany — August 2014

I.   From Albany: Perils of Being a Rich State in the Federal System If the United States were the European Union, New York, Connecticut and New Jersey could be compared to Germany and France, which subsidize less wealthy E.U. members. … Continue reading

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Like Kind Exchanges in 2014: An Oasis of Income Tax Tranquility

High income New York City residents selling fully depreciated real estate this year will incur a capital gains tax of about 39 percent, consisting of a federal tax of 28.5 percent (25 percent on IRC §1250 unrecaptured gain plus 3.8 … Continue reading

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2010 Like Kind Exchange Decisions and Rulings

Like Kind Exchange Decisions & Rulings of 2010 [Note:Excerpted from Like Kind Exchanges of Real Estate Under IRC. §1031 (3rd Ed., 1/11) . View treatise at nytaxattorney.com] I. Use of Replacement Property as Personal Residence Negates Like Kind      Exchange Treatment … Continue reading

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