On June 10, 2020, in Nelson v. Commissioner, T.C. Memo 2020-81, the Tax Court ruled in favor of the IRS and against a taxpayer who attempted to use a defined value provision to value a transfer of assets.
The taxpayer’s
The Tax, Trusts & Estates Law blog published by Cole Schotz P.C. focuses on legal issues related to taxation, estate planning, trusts, and related fiduciary matters. It covers topics such as IRS procedures and relief options for tax elections, charitable and legacy planning strategies, updates on estate and gift tax exclusions and rates, and significant court decisions affecting tax penalties and compliance. The blog also discusses practical considerations in business succession planning, including buy-sell agreements and insurance arrangements. It serves as a resource for developments in tax law, trust administration, estate tax planning, charitable giving, and regulatory compliance relevant to individuals, families, and businesses.
On June 10, 2020, in Nelson v. Commissioner, T.C. Memo 2020-81, the Tax Court ruled in favor of the IRS and against a taxpayer who attempted to use a defined value provision to value a transfer of assets.
The taxpayer’s…
As an estate and trust attorney who has been practicing for over 20 years, I never lose sight of the difficulty we all face when losing a loved one. Often when I meet a client, sometimes for the very first…
The IRS recently issued Notice 2020-39, which offers relief to both qualified opportunity zone funds (“QOFs”) and persons seeking to invest in QOFs who are affected by the global COVID-19 pandemic.
Investors in QOFs who want to defer capital gains…
The global coronavirus pandemic is of course a challenging time. Many businesses have been hard hit and may not recover. Unemployment has skyrocketed. On the other hand, there are many businesses that have been only mildly affected to date.
The…
In order to remove any ambiguity occasioned by prior New Jersey Supreme Court Orders, extending the April 1 and May 1 annual tax appeal filing deadlines for regular and revaluation or reassessment district appeals to “30 days after the Governor…
As the Covid-19 pandemic has swept across the nation and around the world, those of us who practice in the areas of Wills, Trusts and Estates have noted an increase in calls from clients alarmed by what they are seeing…
In light of the coronavirus pandemic and significant economic downturn, this blog post briefly discusses questions that are commonly being asked right now regarding the income tax treatment of cancellation of indebtedness income (“COD”).
The tax code provides that income…
Businesses dealing with the present economic downturn may find relief from taxation and potential tax refund options under existing tax law as recently amended by the CARES Act.
Unlocking the Benefits of Net Operating Loss (“NOLs”) Carrybacks: The 2017 Tax…
On April 9, 2020, the IRS extended certain additional key tax deadlines affecting payments from both individuals and businesses due to the impact of the COVID-19 pandemic. Notice 2020-23 expanded upon prior IRS guidance that extended the dates for taxpayers…
On April 9, 2020, the IRS updated its guidance originally provided in Notice 2020-18, Additional Relief for Taxpayers Affected by Ongoing Coronavirus Disease 2019 Pandemic, to provide extension relief to taxpayers in response to the coronavirus emergency. In addition to…