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Recent Articles & Treatises
- Registration now open for September 17, 2019 CPE Seminar, “IRC Sec. 199A: Wasn’t the Code to be Simplified?” August 26, 2019
- A Journey Through IRC Section 199A: Wasn’t the Code to be Simplified? July 25, 2019
- Tax News & Comment — August 2019 July 25, 2019
- Tax News & Comment – April 2017 March 13, 2017
- Tax News & Comment — May 2016 May 14, 2016
- FROM WASHINGTON & ALBANY — Current Election Probabilities; Tax Plans of Trump and Clinton May 13, 2016
- FROM FEDERAL AND NYS COURTS: Recent Developments & 2015 Decisions of Note May 13, 2016
- IRS & NYS DTF MATTERS: Recent Developments & 2015 Regs. & Rulings of Note May 13, 2016
- Creating and Maintaining Flexibility in Wills and Trusts May 13, 2016
- Escaping the Quandary Posed by Unreported Foreign Accounts May 13, 2016
- Like Kind Exchanges Alive and Well: An Update May 13, 2016
Most Popular
- Valuation Discounts for LLCs
- Distributable Net Income and Income in Respect of a Decedent
- The IRC § 2036 Trap in Planning With FLPs & Grantor Trusts
- Defeating The Right of Election in EPTL § 5-1.1-A
- Legal Basis for Seeking Abatement of New York State Tax Penalties
- Installment Sales in Real Estate Transactions
- New York's Revised Decanting Statute Under EPTL §10-6.6
- Marshalling Estate Assets
- Taxation of Foreign Nongrantor Trusts: Throwback Rule
- Qualified Personal Residence Trusts (QPRTs)
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
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
Posted in Estate Planning, Federal Gift Tax, Federal Income Tax, Grantor Trusts, Income Taxation of Nongrantor trusts, Portability
Tagged asset sales to grantor trusts, final regs on portability, final regs on section 67(a), last deceased spouse, new york "throwback" rule for trusts, New York Amendments to Gift and Estate Tax, New York estate tax exemption, new york obviates grantor trusts, New York portability, new york trust changes, new york's "cliff" estate rule, plr 20130002 new york, Portability, qtip contingency plr 20140011, relief from late portability elections, Taylor v. NYS Tax Commission
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
Posted in Federal Income Tax, Federal Tax Litigation, IRS, IRS Rulings & Regulations
Tagged effect of letter rulings, effect of PLRs, income tax, irs, IRS letter rulings, Pre-submission conference, Private Letter Ruling Requests, Private Letter Rulings, Rev. Proc. 2015-1, Ruling Request Submission, User Fees for PLRs
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
Posted in Federal Income Tax, From Albany, From Washington, Like Kind Exchanges, New York State Income Tax
Tagged 1031, 1031 exchange, Congress, federalism, high income tax states, new york estate tax, President Obama, president obama tax proposals, states with no income tax, tax legislation, tax planning, unequal taxation in states
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
Posted in Like Kind Exchanges
Tagged 1031, 1031 exchange, like kind exchange, tax attorneys, tax law, tax lawyers
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 →