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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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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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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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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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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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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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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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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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