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Navigating I.R.C. §2036 Tax Planning with Florida Law
For many years, a common estate planning technique has been to create a partnership or limited liability company (LLC) to hold valuable property and then transfer ownership interests in the LLC to an...
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Preparer Penalties: The Thin Line Between Tax Advisor and Return Preparer
The IRS has issued over 1.8 million preparer tax identification numbers (PTINs) since September 2010. Of these, nearly 700,000 remain active.[1] This number, however, paints only a small portion of the...
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Expatriation from the United States: The Inheritance Tax Under I.R.C. §2801
In addition to the Exit Tax, the Heart Act added a new federal transfer tax, which imposes an “Inheritance Tax” on certain gifts or bequests (testamentary dispositions) made by a “covered expatriate”...
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Reflections on a Vetoed Bill
On June 24, Gov. Ron DeSantis vetoed Senate Bill 1382, preventing the Department of Revenue from moving forward with sweeping changes that would have expanded the department’s authority while...
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QDRO Math: Advice to Plan Administrators in Florida
Protecting retirement fund assets for public policy purposes has been deeply rooted in our nation’s history for as long as retirement plans have been in existence.[1] That history shows a desire to...
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Innocent Spouse Relief from Joint and Several Federal Tax Liability: Updates,...
Married couples can choose to file either joint tax returns or separate tax returns for federal income tax purposes.[1] In almost every situation, a married couple will have a lower tax liability if...
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Internal Revenue Code §1202 and You: Analyzing Exclusion of Gain on Sales of...
Section 1202 of the Internal Revenue Code provides a way for taxpayers to exclude much, if not all, of the gain on the sale of stock in certain small businesses. With the deal volume of recent years,...
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Designing Trust Systems for Florida Residents: Planning Strategies, Things...
Revocable and irrevocable trusts are commonly used as the primary platforms for estate and financial planning for individuals, married couples, and families in general. While most Floridians use trusts...
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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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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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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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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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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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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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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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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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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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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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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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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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