The IRS recently issued Revenue Procedure 2022-19, which permits S corporations to remedy certain inadvertent terminations of S corporation status and invalid elections without having to request a costly Private Letter Ruling. Previously, the IRS permitted such relief without a Private Letter Ruling in only two limited circumstances – (1) failing to timely file Form
David J. Choyne
Contact: Read more about David J. Choyne
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…
Update – New York Power of Attorney Law Goes Into Effect
By David J. Choyne & Marta J. Paczkowska on
Posted in Legislation
On June 12, 2021, New York’s new Power of Attorney law (A.5630-A/S.3923-A) went into effect. As a reminder, the law simplifies New York’s Power of Attorney form and implements penalties for improper rejection of a New York Power of Attorney by third parties. A Power of Attorney that was executed under a prior version of…
New York Modifies Power of Attorney Law to Simplify Form
By David J. Choyne on
Posted in Legislation
Marta J. Paczkowska, Law Clerk at Cole Schotz, co-authored this blog.
On December 15, 2020, Governor Andrew Cuomo signed a bill into law that simplifies New York’s Power of Attorney form and implements penalties for improper rejection of a New York Power of Attorney by third parties.
The new law (A.5630-A/S.3923-A), which goes into effect…
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…