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…
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…
In the 2017 Tax Act, Congress adopted Code §1061, a provision which affects non-corporate holders of certain carried interests, which the new law refers to as applicable partnership interests (“APIs”). Under the new law, certain long-term capital gains (“LTCGs”) relating to APIs may be recharacterized as short-term capital gains (“STCGs”) unless the gains are from…
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…
New Jersey Governor Phil Murphy and State Democratic leaders announced yesterday a revised fiscal year 2021 budget that raises the State’s gross income tax rate on income for families now earning between $1 million and $5 million.
Currently, the State’s top tax rate for income earned in excess of $1 million through $5 million pay…
