Estate Planning

10
Sep

WHY YOU SHOULD ALWAYS PAY YOUR PAYROLL TAXES: A PRIMER ON TRUST FUND RECOVERY PENALTIES (PART 1)

By: Kevin Murphy, Esq. PART ONE When we discuss potential liability for the Trust Fund Recovery Penalty (TFRP)- I.R.C. § 6672, we often find the need to explain how payroll taxes work.  Many clients, some lawyers and accountants and unfortunately even some IRS agents and Assistant U. S. Attorneys don’t really understand what constitutes a trust fund liability.  Everyone has

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3
Jul

WHY YOU NEED ESTATE PLANNING

By: Ruth Wiseman, Esq. We all know the old saying that there are only two certainties in life – Death and Taxes. While this is an unfortunate truth, the good news is that with the right planning you can avoid unnecessary headaches while dealing with or preparing for both. Specifically, when it comes to Estate Planning, taking the right steps

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11
Apr

Are 2018 State and Local Real Property Taxes Paid in 2017 deductible or not? The Answer’s in the Statute.

By: John L. Marien On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act.  In light of the various tax cuts contained in the revisions to the Internal Revenue Code, Congress was compelled to formulate legislation that would recover some of the lost revenue.  One provision aimed at recovering a portion of this revenue loss

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5
Jan

What Tax Reform Could Mean For Your Clients

By: Michael J. Tedesco, Esq. On December 22nd, 2017 with one stroke of a pen, president Trump signed into law the most sweeping tax law changes in a generation. For the first time in over 30 years tax professionals will confront significant changes in the tax law that will impact planning, reporting and enforcement matters. While the true impact of

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30
Apr

Aragona Trust: Passive Activity Losses, the Material Participation Exception, and the Medicare Tax

Generally speaking, most taxpayers, including individuals and trusts, are denied the use of their passive activity losses and credits to offset ordinary income under the passive activity loss (“PAL”) rules of Section 469 of the Internal Revenue Code (the “I.R.C.”).  These PAL rules prevent investors from utilizing losses incurred in income-generating activities in which they are not materially involved, thus

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1
Apr

Shedding Some Light on the PFIC Regime

By: Kenneth A. Grossberg Today, United States investors in foreign corporations often find themselves with an unknown or unexpected problem.  In particular, investors in mutual funds organized outside of the United States have run into problems with the Passive Foreign Investment Company (“PFIC”) rules.  As the application of these rules can result in severe tax consequences to the unwary and unprepared,

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1
Apr

IRS Launches Compliance Initiative on Estate & Gift Tax

The IRS has recently launched a compliance initiative aimed at identifying taxpayers with potential estate or gift tax liabilities or related compliance issues. As part of this initiative, the IRS has requested and received information from state and county authorities in Connecticut, Florida, Hawaii, Nevada, New Hampshire, New Jersey, New York, North Carolina, Ohio, Pennsylvania, Tennessee, Texas, Virginia, Washington, and

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10
Jun

Foreign Bank Account Reporting FBAR and the IRS Voluntary Compliance Initiative of 2009

On March 23, the IRS announced its voluntary compliance initiative to encourage disclosure of foreign bank account details, such as previously undisclosed foreign financial accounts and entities. The policy will remain in place until Sept. 23, 2009. Taxpayers having a financial interest or signature authority over one or more foreign bank accounts worth $10,000 or more should be aware that

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