“With Liberty and Justice (and Death Taxes) for All” …. Biden Proposal Changes the Taxation Game for Gifts and Inheritances (Part I)

Today's post is in two parts and was written with my colleague John Richardson, J.D. On March 28, President Joe Biden released the FY2023 Budget, also known as the Green Book, available here.   The Green Book is not proposed legislation, but it might be viewed as a kind of reading of the tea leaves showing … Continue reading “With Liberty and Justice (and Death Taxes) for All” …. Biden Proposal Changes the Taxation Game for Gifts and Inheritances (Part I)

IRS Made a Big Announcement – So, Can a Taxpayer Now Rely on IRS FAQ’s?

Despite the Internal Revenue Service (IRS) recent announcement, it seems to me that the answer is still “Well, it depends!” Here’s my take on the what the IRS said, which to be honest, was just a bit more clear than mud. Taxpayers and tax pros should always look first to whether the FAQ is published … Continue reading IRS Made a Big Announcement – So, Can a Taxpayer Now Rely on IRS FAQ’s?

Is There Really a “Solution” for Crypto Tax Noncompliance?

Now that the US Congress and the Internal Revenue Service (IRS) have digital asset transactions firmly in the crosshairs for investigations and reporting, we are in the midst of what I will call crypto-currency tax anxiety.  Millennials may make up a larger group of persons dealing with crypto, and may be very concerned about prior … Continue reading Is There Really a “Solution” for Crypto Tax Noncompliance?

The Federal Transfer Certificate:  What Foreign Investors Into the USA Need to Know

Individuals living outside of the US who inherit a US asset from a foreigner may be in for some surprises. If the decedent is an individual who is treated as a nonresident alien individual (NRA) for US estate tax purposes, his heirs often  have a difficult time obtaining actual title to the US asset they … Continue reading The Federal Transfer Certificate:  What Foreign Investors Into the USA Need to Know

Checked “YES” to the Crypto Question on Form 1040? Have NFTs? Get Ready….  

It’s been no secret that the Internal Revenue Service (IRS) has cracked down on crypto.  With many more taxpayers investing in cryptocurrencies the agency has targeted crypto investors who are often not complying with the US tax rules (many unknowingly). IRS “John Doe” subpoena activity of crypto exchanges has been successful with the biggies such … Continue reading Checked “YES” to the Crypto Question on Form 1040? Have NFTs? Get Ready….  

What does Senator Warren’s Proposed Wealth Tax Mean for You?

The ‘‘Ultra-Millionaire Tax Act of 2021’’ (the “Act”) was proposed by Democratic Senators Elizabeth Warren and Bernie Sanders on March 1, 2021.  Like all other tax proposals I have seen in my over 35+ years of tax practice, once the bee is in the bonnet, legislation will inevitably, inexorably, eventually blossom and flourish.  The Act … Continue reading What does Senator Warren’s Proposed Wealth Tax Mean for You?

What a Mess: Debt Forgiveness and the American Abroad  

Imagine you are an American taxpayer living overseas. Like so many other Americans you are facing financial hardships wrought by COVID-19.  You have a car loan you cannot pay and mounting credit card debt. Like an angel from above, your creditors agree to forever forgive some of the amounts you otherwise owe them.  You cannot … Continue reading What a Mess: Debt Forgiveness and the American Abroad  

Lifting the Veil on US Shell Companies – Third Attempt to Force Beneficial Ownership Registers

Play it again (Uncle) Sam! Two US senators are trying yet again to enact a law mandating creation of a national database of beneficial owners of US businesses.  So far we have seen two unsuccessful attempts by lawmakers for mandatory beneficial ownership registers in the USA. The latest borrows heavily from the two bills that have … Continue reading Lifting the Veil on US Shell Companies – Third Attempt to Force Beneficial Ownership Registers

Handle With Care: How Sharia Law and U.S. Tax Law Affect the Foundations Regime in the United Arab Emirates

Proud to announce publication of my article Handle With Care: How Sharia Law and U.S. Tax Law Affect the Foundations Regime in the United Arab Emirates in Tax Notes International (TNI) Vol. 98 No. 5 May 4, 2020. Available at no cost on SSRN. The article discusses the US tax treatment of the newest "foundations" … Continue reading Handle With Care: How Sharia Law and U.S. Tax Law Affect the Foundations Regime in the United Arab Emirates

IRS Provides CARES Act Guidance for Taxpayers with NOLs

As set out in detail in my earlier blog post, the CARES Act amended Internal Revenue Code section 172(b)(1) to provide for a carryback of any net operating loss (NOL) arising in a tax year beginning after December 31, 2017, and before January 1, 2021, to each of the five tax years preceding the tax … Continue reading IRS Provides CARES Act Guidance for Taxpayers with NOLs