The 2017 Tax Act made life harder on individuals living in high tax states (such as New York, New Jersey, and California) by limiting the deduction for state and local taxes (“SALT”) to $10,000. In an attempt to circumvent this restriction, several states have adopted a new pass-through entity tax imposed on partnerships, LLCs, and
Entity Taxation
Nelson: IRS Prevails in Defined Value Provision Case
By Steven M. Saraisky & David J. Choyne on
On June 10, 2020, in Nelson v. Commissioner, T.C. Memo 2020-81, the Tax Court ruled in favor of the IRS and against a taxpayer who attempted to use a defined value provision to value a transfer of assets.
The taxpayer’s primary business was in heavy equipment relating to the oil and gas industry. The…
The CARES Act and Effects on Charitable Contributions
The coronavirus outbreak, the subsequent passage of the CARES Act by the federal government, and current low interest rates have changed the landscape of charitable contributions and planning in 2020.
Charitable Contributions
The CARES Act changes the limitations on charitable giving to encourage individuals and corporations to make cash contributions to public charities.
- Above-the-line deduction
…
NJ Tax Talk: New Bypass For SALT Deduction Cap
By Steven M. Saraisky & Reuben Muller on
New Jersey has enacted legislation that gives business owners of pass-through entities a way to bypass the $10,000 limit on state and local tax deductions.
The $10,000 state and local tax limitation was implemented under federal law in the Tax Cuts and Jobs Act.[1] The law has been controversial because of its disproportionate effect on…
Supreme Court Unanimously Rules that States Cannot Tax Trusts Based Solely on Location of Beneficiaries
In a closely-watched decision, the U.S. Supreme Court unanimously ruled that a beneficiary’s residence within a state alone does not subject a trust to such state’s income tax. In North Carolina Dept. of Revenue v. Kimberley Rice Kaestner 1992 Family Trust, No. 18-457 (U.S. Jun. 21, 2019), North Carolina attempted to tax the income…