The IRS recently issued Revenue Procedure 2022-19, which permits S corporations to remedy certain inadvertent terminations of S corporation status and invalid elections without having to request a costly Private Letter Ruling. Previously, the IRS permitted such relief without a
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Charitable Planning Update: Yvon Chouinard Donates Patagonia Stock to Two Nonprofits
Many of our clients are charitably inclined, and incorporate charitable planning into their overall estate planning. This can be as simple as making gifts to charities during life or via specific bequests in a Will. In addition, clients create donor…
2022/2023 Estate and Gift Tax Update
The IRS has announced the official estate and gift exclusion amounts for 2023.
For an estate of any decedent dying during calendar year 2023, the applicable exclusion is increased from $12.06 million to $12.92 million. This change increases not…
Important Supreme Court Decision will Decide how Non-Willful FBAR Penalties are Calculated
By Ram Shastri & Reuben Muller
This fall, the Supreme Court is set to hear an important case regarding the interpretation of the law that provides for penalties for failing to file an FBAR. The case will impact many taxpayers who have already been penalized and…
The Insurance-Only LLC – A Consideration for Buy-Sell Agreements
When business owners have partners and consider their succession planning, the topic of a buy-sell agreement comes up. This post discusses the possible use of an “insurance-only LLC” as part of a buy-sell.
A buy-sell agreement sets the terms of…
Newly Enhanced Estate Tax Portability Relief under Revenue Procedure 2022-32
Effective July 8, 2022, the IRS issued Revenue Procedure 2022-32 to supersede Revenue Procedure 2017-34 and now allow for a late estate tax exemption portability election to be made up to five (5) years from a deceased spouse’s death. Previously,…
Common Errors that Arise during an Estate Administration
In our busy practice, we tend to see certain recurring errors. In particular, we see planning errors that arise during the estate administration process after someone dies. Below are a few of these common errors, and, in the spirit of,…
Tax Court Shuns Traditional Survey Derived Capitalization Rate Determinations and Champions Reliance Upon The Band of Investment Technique Instead
In a recently decided case 3 University Plaza SPE, LLC v. City of Hackensack 5002-2014, 1670-2015, 3553-2016, 1163-2017, 3768-2018, 12891-2019 – 3 University Plaza SPE LLC, et al. v. Hackensack City (njcourts.gov) concerning a large 225,000 square foot class A…
2022 Changes to Estate and Gift Tax Exclusions
The IRS released Revenue Procedure 2021-45 which announces the increase in 2022 of the estate, gift and generation-skipping transfer tax applicable exclusion amounts from $11.7 million to $12.06 million. The applicable exclusion amounts currently remain scheduled to expire on December…
“Accidental Americans” Must Pay US Tax on Worldwide Income and Provide Detailed US Tax Reporting
We have had several matters recently with “Accidental Americans” – that is, non-US persons who became US tax residents by staying in the US for a sufficient number of days.
This frequently happens in an understandable way, and involves a…