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Articles & Seminar Materials
- June 5 NYS Tax Litigation Seminar: Completion Certificate June 2, 2025
- June 5 NYS Tax Litigation Seminar — Outline May 31, 2025
- June 5 Tax Litigation Seminar — Supplementary Materials May 14, 2025
- June 5 CPE Seminar: NYS Tax Litigation — Practice & Procedure April 28, 2025
- March 13 CPE Seminar: Supplementary Materials March 4, 2025
- Income Taxation of New York Trusts & 2025 Planning Strategies March 4, 2025
- Webinar Recording of 1031 Final Regulations Seminar January 16, 2025
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Tag Archives: irs
Like Kind Exchanges Alive and Well: An Update
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
Posted in Like Kind Exchanges, News
Tagged 1031, 1031 exchange, income tax, irs, like kind exchange, tax planning
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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
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
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IRS & NYS DTF Matters: Recent Developments & 2013 Regs. & Rulings of Note
I. IRS Matters Final Regulations For Health Insurance As of January 1, IRC § 5000A requires that all “non-exempt” individuals obtain “minimum essential healthcare coverage.” Final regulations governing penalties for noncompliance have been issued. (T.D. 9632). The regulations provide, inter … Continue reading
Posted in Gift & Estate Tax Decisions of Note, IRS, IRS Matters, IRS Rulings & Regulations, NYS Dept. of Tax'n & Finance
Tagged delaware nongrantor trusts, Health Insurance Regulations, irs, late s corporation election, mcneil v. Pennsylvania, net investment income tax, nys suspension of drivers' license tax, nys warrantless income executions, option reporting for brokers mandatory, PLR 201310002, regulations for tangible property, relief from unnecessary qtip elections, Rev. Proc. 2013-35, Taylor v. NYS Tax Commission, treasury
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Summary of Tax Changes Under American Taxpayer Relief Act of 2012
(1) Ordinary Income. Beginning in the 2013 taxable year, single taxpayers with ordinary income over $400,000 and married taxpayers filing jointly whose income exceeds $450,000 will be subject to a new higher 39.6 percent tax rate. [These … Continue reading
Posted in News
Tagged Congress, estate tax, gift tax, income tax, irs, Medicare, President Obama, tax legislation, tax planning, treasury
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Second Term Blues Visit President Obama
Congress Grants One Year Reprieve For Affordable Care Payments President Obama has suffered a precipitous decline in his approval rating since late April, when that indicator was at 50 percent. Today, Mr. Obama enjoys the approval of only 45 percent … Continue reading
Posted in From Washington, Tax News & Comment
Tagged Congress, income tax, irs, President Obama, tax lawyer, tax legislation, tax planning, treasury
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Recent IRS Developments — October 2031
I. Taxpayer Advocate Issues 2014 Report National Taxpayer Advocate Nina Olson recently issued a report detailing the issues on which the Taxpayer Advocate Service (TAS) will focus during the fiscal 2014 tax year. IR-2013-63. The Taxpayer Advocate is required by … Continue reading
Posted in IRS, Tax News & Comment
Tagged Congress, estate planning, gift tax, income tax, irs, President Obama, tax legislation, tax planning, treasury
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Update on 11th Annual Tax Symposium in November
Like Kind Exchanges of Real Estate Under IRC §1031 (TAX CPE) (CLE); Course 3047; Lecturer: David L. Silverman, J.D., LL.M. (Taxation) The Section 1031 like-kind exchange is a powerful tax-deferral technique that has, for the most part, escaped Congressional scrutiny. … Continue reading
Tax News & Comment — October 2013
Posted in News, Tax News & Comment
Tagged 1031, applicable exclusion amount, asset protection, audit, completed gift, Congress, credit shelter trust, deferred exchange, Delaware Asset Protection Trust, disclaimers, division of tax appeals, estate attorney, estate planning, estate tax, form 709, gift tax, income tax, irs, like kind exchange, marital deduction, new york estate tax, President Obama, probate, QTIP, QTIP election, qualified intermediary, statute of limitations, surviving spouse, tax appeals tribunal, tax attorney, tax fraud, tax lawyer, tax legislation, tax planning, treasury, valuation discount
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IRS Ruling Provides Basis for Asset Protection Trust in Nevada
I. Tax & Asset Protection Benefits of PLR 201310002. New York imposes among the highest level of income tax of all states. New York City residents pay even more tax for the privilege of residing there. Income is taxed to … Continue reading
Posted in Asset Protection, Asset Protection Trusts, Delaware Asset Protection Trusts, Estate Planning, Trusts
Tagged asset protection trust, delaware trust, DING Trusts, grantor trust, IRC 674, IRC 677, irs, nevada trust, new york resident trust PLR 201310002, NING Trusts, Tax Law 605(b)(3)(D)(i)
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Tax News & Comment — February 2013
View in PDF: Tax News & Comment — February 2013
Posted in Tax News & Comment
Tagged applicable exclusion amount, asset protection, asset protection trusts, credit shelter trust, estate attorney, estate planning, estate tax, gift tax, gross estate, GST, ILIT, irs, like kind exchange, marital deduction, New York decanting statute, new york estate tax, President Obama, probate, QTIP, tax attorney, tax lawyer, tax legislation, tax planning
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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 1031, applicable exclusion amount, asset protection, asset protection trusts, carryover basis, credit shelter trust, division of tax appeals, estate planning, estate tax, gross estate, irs, new york estate tax, qualified intermediary, statute of limitations, surviving spouse, tax appeals tribunal, tax legislation, tax planning
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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 1031, applicable exclusion amount, asset protection, asset protection trusts, audit, carryover basis, completed gift, Congress, credit shelter trust, Delaware Asset Protection Trust, disclaimers, division of tax appeals, estate planning, estate tax, gift tax, gross estate, ILIT, income tax, irs
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Tax News & Comment — August 2014