Tax Law News and Insights

INTRODUCTION When a U.S. person disposes of a business situated in a foreign country, the nature of the gain as capital or ordinary and the source of the gain may sound like simple issues that require simple tax advice. It may, however, turn out to be far more complex as...

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A recent IRS notice has reinvigorated the discussion around utilizing limited liability companies (LLCs) in connection with Section 501(c)(3) tax-exempt organizations, including charitable health systems and related health care organizations. More specifically, last October, the IRS released Notice 2021-56, which provided more definitive guidance on LLCs obtaining their own Section 501(c)(3)...

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Like many states, New York has a progressive tax rate that starts at 3.06% for estates at or over $5.74 million and extends up to 16% for estates that exceed the exemption limit by $10.1 million or more. But unlike other states, if the estate exceeds the exemption level by...

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