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IRS Issues Notice 2022-53 and Will Waive 50% Excise Tax on Certain Required Minimum Distributions from Retirement Plans in 2021 and 2022
Federal Taxation
On October 7, 2022, the Internal Revenue Service issued Notice 2022-53,[1] which provides much-needed transition relief in…
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The IRS Extends the Transition Period for Enhanced R&D Tax Credit Reporting Requirements
Federal Taxation
On Friday, September 30, the Internal Revenue Service (the “Service”) set forth administrative guidance indicating that…
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IRS Gets a Boost–With Possible Conditions
Federal Taxation
A better, stronger, faster Internal Revenue Service may soon be tracking down more wealthy tax cheats, thanks to the…
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An Insider’s Guide to IRS Examination of Financial Products and Transactions
Federal Taxation
In my prior role, I was involved in numerous examinations of financial products and transactions as a Large Business and…
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How You Can Lose a Passport Due to Tax Debt
Federal Taxation
If you owe enough in delinquent American federal taxes, the U.S. government can take your passport. The IRS certifies…
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Qualified Retirement Plan Design for Closely Held Businesses
Income Taxation
I. INTRODUCTION The primary goal of most employers in establishing any type of retirement savings program is to…
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Testamentary Transfers to Non-Citizen Spouses
Estate Taxation
Transfers between U.S. Citizen Spouses -— The Marital Deduction U.S. citizens may delay the imposition of either the U.S.…
Read More
What Does the Use-It-or-Lose-It Proposition Really Mean Estate Tax Planning-Wise?
Estate Taxation
In 2022, taxpayers have at their disposal a $12,060,000 Basic Exclusion Amount (BEA) for federal gift and estate tax…
Read More
Digital Assets: A Fad, or Something More?
Income Taxation
Foodies love their fads and crazes: Kobe beef, bluefin tuna sashimi, even the seasonal pumpkin spice latte. But truffles are…
Read More
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