Related Party Loans
If you’ve been around closely held businesses long enough, you know that a transfer of money between a business and its owner, or between two related businesses, is sometimes characterized by the parties as a loan (“related
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The Limited Partner Exclusion From Self-Employment Tax – But Who Is A Limited Partner?
An Agency Under Siege
The mission statement of the IRS reminds taxpayers that it is their responsibility to understand and meet their tax obligations, while it is the role of the IRS to “enforce the [tax] law with integrity and fairness
Terminating a Trust? Don’t Forget to Consider This Tax Issue
Remember Taxes
Every conveyance of property or of an interest in property from one person to another is prompted, or at least influenced, by economic considerations. The parties to the transaction may swap properties, or one party may transfer a
State Taxation of a Nonresident’s Gain from the Sale of Stock –The Shot Heard Round the Country?
Two Camps
Last month, Bloomberg carried an article about a “small but growing trend” of states that are either cutting their individual income taxes or phasing them out entirely.[i]
According to the article, the states adopting these measures have
Observations on Charities, Taxes, and Cash Flow
Legal Laissez-Faire?
Few provisions of the Code have a single, clear meaning that leaves no room for interpretation. Even many of those that, on the surface, appear fairly straightforward, are usually open to alternative “understandings.”
In the absence of continuous
“Hey Mom, Can I Have A Few Bucks?” Is It A Loan? A Gift? A Little of Each?
Intrafamily Transfer
A parent will sometimes transfer money to a child to enable the child to make an investment that the child could not otherwise make on their own.
For example, the child may have identified an attractive business opportunity
Transferring the Family Business To A Private Foundation? Are You Sure About That?
Do This But Not That
Charitable organizations are dependent, in no small part, upon the financial support of many successful business owners. The generosity of these individuals and their organizations may be a manifestation of several factors including, for example,
NYC Transfer Tax, Charities, and Single Purpose LLCs – Are Lenders Beneficiaries?
NYC Transfer Tax
According to the New York City Comptroller, the City collected approximately $1.13 billion in Real Property Transfer Tax (“RPTT”) in the FY 2024. The Comptroller’s Office has forecast that $1.21 billion of RPTT will be collected in
New York Sales Tax: When a Responsible Person Acts Irresponsibly
Tax Receipts
Late last year, the Office of the State Comptroller (the “OSC”) estimated that sales and use tax receipts would increase by 2.3% in the SFY 2024-2025.[i]
The OSC also projected that collections from sales and use taxes
Business Owner Borrows from Their Private Foundation – A Different Form of “For Profit Philanthropy”?
Good Intentions
Many successful business owners attribute some part of their success to their community. For some of these owners, it is not enough to simply acknowledge this “debt”; they feel an obligation to share some of their financial success