Effective July 8, 2022, the IRS issued Revenue Procedure 2022-32 to supersede Revenue Procedure 2017-34 and now allow for a late estate tax exemption portability election to be made up to five (5) years from a deceased spouse’s death. Previously, this window was only two (2) years from the deceased spouse’s death. Revenue Procedure 2022-32
Tax
Tax Court Shuns Traditional Survey Derived Capitalization Rate Determinations and Champions Reliance Upon The Band of Investment Technique Instead
By Carl A. Rizzo on
Posted in Tax
In a recently decided case 3 University Plaza SPE, LLC v. City of Hackensack 5002-2014, 1670-2015, 3553-2016, 1163-2017, 3768-2018, 12891-2019 – 3 University Plaza SPE LLC, et al. v. Hackensack City (njcourts.gov) concerning a large 225,000 square foot class A office building, the Tax Court addressed the valuation community’s on-going debate as to whether certain…
2022 Changes to Estate and Gift Tax Exclusions
By David J. Choyne & Gary A. Phillips on
The IRS released Revenue Procedure 2021-45 which announces the increase in 2022 of the estate, gift and generation-skipping transfer tax applicable exclusion amounts from $11.7 million to $12.06 million. The applicable exclusion amounts currently remain scheduled to expire on December 31, 2025, which would result in a reduction in the exclusion amounts to $5 million…
“Accidental Americans” Must Pay US Tax on Worldwide Income and Provide Detailed US Tax Reporting
By Steven M. Saraisky on
Posted in Tax
We have had several matters recently with “Accidental Americans” – that is, non-US persons who became US tax residents by staying in the US for a sufficient number of days.
This frequently happens in an understandable way, and involves a non-US person who has family in the US. The non-US person comes to visit his…
Starting an Active Business in an Opportunity Zone
By Steven M. Saraisky on
Posted in Legislation, Tax
This short article outlines the requirements for starting an active business in a qualified opportunity zone (“QOZ”).
The US tax legislation that created QOZs was enacted in early 2018, and is intended to encourage long-term investment in economically distressed communities. The IRS issued two substantive sets of proposed regulations outlining rules for QOZ investments (in…