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
Tax
“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…
Carried Interests: Final Capital Gain Recharacterization Rules Released
By Philip Hirschfeld on
Posted in Tax
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…
SALT CAP Workaround – An IRS Holiday Gift
By Philip Hirschfeld on
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…