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SCOTUS Addresses Constitutional Challenge to Mandatory Repatriation Tax
Federal Taxation
In Moore v. U.S. (36 F. 4th 930), the U.S. Supreme Court ruled on a constitutional challenge of IRC section 965, the…
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Estate of Fields v. Comm’r—Bad Facts Family Limited Partnership Causes Estate Tax Inclusion under IRC Section 2036(a)(1) and (2) with Accuracy-Related Penalty Imposed
Federal Taxation
Estate of Fields v. Commissioner, T.C. Memo. 2024-90 (Sept. 26, 2024) (Copeland, J.), provides a textbook example of a “bad…
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IRS to Stop Automatically Assessed 3520 Late Filing Penalty on Large Foreign Gifts
Federal Taxation
At the end of October 2024, the IRS announced that it will no longer automatically assess penalties for late reporting of…
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AI in Accounting: Leveraging the New Era of Efficiency and Insight Part 2
Corporate Taxation
This is part two of a two-part series on Leveraging AI for Tax Resolution and Client Success. To view part one, please click…
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Does a Transfer on Death Deed Live up to the Hype?
State Taxation
Effective July 19, 2024, the Heirs Property Protection and Deed Theft Prevention Act of 2024 became law in New York. With the…
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A Test of New York State’s Infamous Convenience Rule
State Taxation
The case of Scott and Elizabeth Bryant was heard in the Division of Tax Appeals by Administrative Law Judge Alexander…
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The Sunset of the Doubled Estate, Gift, and GST Tax Exclusion Amounts after December 31, 2025 – What High Net Worth Individuals and Family Offices Need to Know About It
Federal Taxation
In the world of high-net-worth individuals and their financial advisors, the sunset of certain provisions of the 2017 Tax…
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AI in Accounting: Leveraging the New Era of Efficiency and Insight
Corporate Taxation
This is part one of a two-part series on Leveraging AI for Tax Resolution & Client Success. Part two will focus on tips…
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Long Term Care and Asset Protection Planning
State Taxation
It is estimated that 70% of adults aged 65 years and older will require long-term care at some point in their lives.…
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