Larry's Tax Law

It is hard to believe it, but 2017 is close to an end.  We have had a truly interesting year in the world of tax law.  Attempts to eliminate the Affordable Care Act and the enactment of the Tax Cuts and Jobs Act in late December are highlights of this past year.  In early January, I plan to provide readers with a multi-part series on the new tax law.

During the past 12 months, we have explored several topics, including:

The NYU 76th Institute on Federal Taxation (IFT) is taking place in New York City on October 22-27, 2017, and in San Francisco on November 12-17, 2017.  This year, I will be presenting my latest White Paper, The Built-in Gains Tax Revisited.  My presentation will include a discussion about the history of the tax; application and impact of the tax; ways to avoid or potentially minimize the tax; the complexities of Code Section 1374 and the regulations promulgated thereunder; valuation issues; planning opportunities; traps that exist for the unwary; relevant cases and rulings; and practical tax practitioner guidance.

The IFT is one of the country's leading tax conferences, geared specifically for CPAs and attorneys who regularly are involved in federal tax matters.  The speakers on our panel include some of the most preeminent tax attorneys in the United States, including Jerry August, Terry Cuff, Wells Hall, Karen Hawkins, Stephen Looney, Stephen Kuntz, Mark Peltz and Bobby Philpott.  I am proud to be a part of IFT.

This will be my fifth year as an IFT presenter, and I am speaking as part of the Closely Held Business panel on October 26 (NYC) and November 16 (San Francisco).  As in previous years, the IFT will cover a wide range of fascinating topics, including tax controversy, executive compensation and employee benefits, international taxation, corporate taxation, real estate taxation, partnership taxation, taxation of closely-held businesses, trusts and estates, and ethics.

I hope you will join us this year for what will be a terrific tax institute.  Looking forward to seeing you in either New York or San Francisco!

View the complete agenda and register at the NYU 76th IFT website.

Please join me on June 29, 2017 in Portland, Oregon, for what will be a dynamic presentation on the new partnership audit rules by Jerald August.  Jerry is a Partner in the preeminent New York City-based boutique tax firm Kostelanetz & Fink, LLP.  He has served as a chair of NYU's Institute on Federal Taxation for a number of years and specializes in federal and state income taxation, including taxation of pass-thru entities and tax controversy.  Jerry is not only one of the brightest tax lawyers you will ever meet, he is an outstanding speaker.  We are very fortunate to have him present at the Portland Tax Forum on this important topic.  We all need to learn about the new partnership audit rules – they come into play on January 1, 2018.

Please join me at the NYU Summer Institute in Taxation this July in New York City. This year, I will be presenting "Entity Classification – Another Look at the Check-the-Box Regulations" on Day 2 (July 27) of the Institute’s Advanced Income Tax and Wealth Planning Conference, where I will discuss recent developments, flexibility and planning opportunities created by the regulations, traps that exist for the unwary, and practical tax practitioner guidance.

It is hard to believe, but 2016 is close to an end. The year has proven to be a quite fascinating year in the world of tax law. Given the results of November’s presidential election and the composition of the House and the Senate, 2017 should be even more intriguing in terms of tax law developments. I plan to report these tax developments as they occur in the new year. Stay tuned!

During the past twelve months, we have explored numerous tax topics, including:

• • The rise and fall of Oregon’s proposed Measure 97;
  • The saga of former U.S. Tax Court Judge Diane L. Kroupa, including her original indictment, the allegations against Ms. Kroupa made by her now estranged husband and her eventual guilty plea;
  • The estates of Michael Jackson and Prince;
  • The new partnership audit regime;
  • New IRS Appeals rules and procedures;
  • The deductibility of the expenses incurred in obtaining an advanced degree – Emmanuel A. Santos v. Commissioner, TC Memo 2016-100;
  • Tax laws relating to legalized sales of cannabis; and
  • The tax gap.

As a reminder, you are invited to join me at the NYU 75^th Institute on Federal Taxation (IFT) taking place on November 13-18, 2016 at Hotel del Coronado in San Diego, California.  The IFT is one of the leading tax conferences in the country, geared specifically for CPAs and attorneys who regularly are involved in federal tax matters.  I hope you can attend.

My article about Qualified Subchapter S Subsidiaries was published in the September 2016 issue of the Journal of Taxation, a Thomson Reuters publication.  The article offers an in-depth discussion of the QSub qualification requirements, the election, late filing relief, termination and inadvertent termination relief.  It also provides a broad discussion of various QSub planning opportunities as well as potential pitfalls.  I hope it is informative and offers you some useful information for application in your tax practices.

A copy of the article is available for download on the GSB website.

Please join me at the NYU 75^th Institute on Federal Taxation (IFT) taking place in New York City on October 23-28, 2016, and in San Diego, California on November 13-18, 2016.

The IFT is one of the leading tax conferences in the country, geared specifically for CPAs and attorneys who regularly are involved in federal tax matters.  Now in my fourth year as an IFT presenter, I am pleased to once again speak on the closely-held business panel on October 27 (NYC) and November 17 (San Diego).  My presentation this year will focus on entity classification under the Check-the-Box regulations.  I plan to provide an in-depth view of the regulations, including planning opportunities, traps that exist for the unwary and practical tax practitioner guidance.

As in previous years, the IFT will cover a wide range of fascinating topics, including tax controversies, executive compensation and employee benefits, international taxation, corporate taxation, real estate taxation, partnership taxation, taxation of closely-held businesses, trusts and estates, and ethics.

I look forward to seeing you at IFT in either New York or San Diego!

View the complete agenda and register at the NYU 75th IFT website.

Dear Readers:

It is hard to believe that 2015 is almost at an end.  Although this year has gone by quickly, it has proven to be an interesting year in the world of tax law.  During the past twelve months, we have explored numerous tax topics and developments, including tax extender legislation, IRS budget cuts, leadership changes at OPR, IRC Section 1031 exchanges, tax reform, taxation of cannabis, and offshore voluntary disclosure programs.

I feel especially blessed this year.  The support that I have received from the legal, tax and accounting professions has been overwhelming.  In June, the Oregon State Bar bestowed upon me the Taxation Section Award of Merit.  Then, in September, I was elected to the American College of Tax Counsel.  Without your help, these accolades would not have been attainable.  Thank you.

I would like to invite you to NYU 74^th Institute on Federal Taxation taking place in New York, New York on October 25-30, 2015, and in San Francisco, California on November 15-20, 2015.

The NYU Tax Institute is one of our country’s most pre-eminent tax conferences for CPAs and attorneys. I am proud to be a presenter on the closely-held business panel of the program on Oct. 29 and Nov. 19. This is my third time speaking at the Institute. This year, I will present a newly-written white paper on qualified subchapter S subsidiaries.