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Grandfathered but Modified: The Continuing Federal Tax Treatment of Pre-TCJA...
Florida’s recent alimony reforms have altered the landscape of family law practice. Effective July 1, 2023, Florida eliminated permanent alimony as an available form of alimony in new dissolution...
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Cross-Border Tax Planning with §1202
Section 1202 provides an exclusion from gross income of capital gain derived from the sale of qualified small business stock (QSBS).[1] The QSBS rules were enacted in 1993 to encourage equity...
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Everyone Needs a Donor Advised Fund
In the famous Dr. Seuss story, The Lorax, the Once-ler develops a product he called “a thneed.”[1] In that fictional story, a thneed is a highly sought after and versatile object (made from the...
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Florida’s Taxation of Lease Contracts: What’s Left After the Commercial Lease...
The big story in Florida taxation during and after the 2025 legislative session was the abolishment of Florida’s tax on commercial leases of real property. Florida’s lonely status as the only state...
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Upstream Basis Planning — The Estate Planner’s Income Tax Planning Tool
This article revisits the upstream basis planning opportunity now enhanced by the enactment of the One Big Beautiful Bill Act. The upstream basis plan implicates both federal estate tax and federal...
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When Old Laws Meet New Tech: Florida’s Uncertain Future in State Taxation
The last time Florida decided to be on the cutting edge of state taxes, it did not turn out so well. Facing a revenue shortfall in 1987, the legislature sought new ways to comply with Florida’s...
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When Old Laws Meet New Tech: Florida’s Uncertain Future in State Taxation
The last time Florida decided to be on the cutting edge of state taxes, it did not turn out so well. Facing a revenue shortfall in 1987, the legislature sought new ways to comply with Florida’s...
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SCOTUS Brightens Constitutional Tax Lines Through Contrasting Judicial...
The U.S. Supreme Court ruled on three significant federal tax cases last year. The rulings significantly impact tax policy and illustrate the contrasting perspectives of the justices. The cases address...
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Public Records and Taxpayer Confidentiality
The Florida Constitution establishes a mandate for open records laws and open meetings of public bodies making collegial decisions. This article discusses: 1) the Florida Constitution in the context of...
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Twelve Angry Taxpayers: Why the Constitution Might Guarantee a Jury Trial for...
This article considers the current constitutional status of the Internal Revenue Code (I.R.C.) §6662 accuracy penalties and I.R.C. §6663 penalties (collectively, tax penalties). It has been widely...
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Individual Retirement Accounts: What a Long, Strange Trip It’s Been
In the November/December 2019 issue of The Florida Bar Journal, I outlined individual retirement arrangement/account (IRA) basics and warned readers of the possibility of new legislation then gaining...
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Federal Tax Lien Remedies
Federal Tax liens are rarely just “tax issues” and can impact clients in a multitude of ways across several practice areas. Obviously, they can impact the sale or transfer of real estate in a...
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Taxed by Design? Florida’s Tax on Interior Design Contracts and What To Do...
Florida sales and use tax can be full of surprises. Generally, sales and use tax applies to the sale or purchase of tangible goods, transient rentals, commercial leases, admissions, and a narrow list...
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Putting Carts Before Horses: Why the Taxpayer Failed in Connelly v. United...
On June 6, 2024, the Supreme Court unanimously ruled for the IRS in Connelly v. United States, 144 S. Ct. 1406, 1414 (2024), which held that when determining the value of corporate shares for estate...
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FinCEN Fenced In? CTA Held Unconstitutional, but Filing To Continue
On March 1, 2024, the federal district court for the Northern District of Alabama issued a memorandum opinion, National Small Business United d/b/a National Small Business Association, et al. v....
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Tax Considerations for Contingent Interest and Convertible Debt in...
The treatment of contingent interest and convertible debt in cross-border payment transactions is subject to several provisions of the Internal Revenue Code.[1] To add confusion to the already...
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Pre-Immigration Planning with the Foreign Trust: The Intersection of Income...
A foreign trust is generally treated as a non-resident/non-citizen (NRNC) for U.S. tax purposes. Foreign trusts are therefore subject to U.S. income tax only on U.S. source income.[1] A common strategy...
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The Cashless Real Estate Deal: Beware of Phantom Withholding on Foreign...
Down markets yield an uptick in insolvent real estate transactions, which may result in cancellation of indebtedness income (COD income). Real estate investors across the U.S. have been faced with...
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Foreign Grantor Trust Planning: A Flexible Planning Structure for U.S. Income...
Over the years, U.S. tax practitioners specializing in international taxation have established foreign grantor trusts (FGTs) to assist multi-jurisdictional families with their U.S. tax and succession...
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Corporate Transparency Act Reporting Rules Finalized, But Will Access Issues...
As of this writing (June 15, 2023), the Corporate Transparency Act (CTA)[1] is scheduled to take effect on January 1, 2024. An earlier article[2] raised several questions in anticipation of rules to be...
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