‘Tis the season of giving, and even the Internal Revenue Service is feeling generous, with proposed regulations that would allow taxpayers to take advantage of the increased exemption amount for estate and gift taxes without fear of retroactive taxation. The federal transfer taxation system is based on the fair market…

The Opportunity Zone program presents a unique opportunity for a taxpayer to defer the capital gains tax by investing the proceeds of a realized capital gain in a Qualified Opportunity Fund (“Opportunity Fund”) holding certain property in a Qualified Opportunity Zone (“Opportunity Zone”). The goal of the Opportunity Zone program…

Public Law 115-97, more commonly known as The Tax Cuts and Jobs Act, added Sections 1400Z-1 and 1400Z-2 to the Internal Revenue Code (the “Code”). Sections 1400Z-1 and 1400Z-2 allow a taxpayer to defer paying taxes on capital gains by investing such capital gains in a Qualified Opportunity Fund (“Opportunity…

The owners of pass-through entities: partnerships (including limited liability companies—LLCs—taxed as partnerships) and S corporations, must pay tax on their share of the entities’ profits, irrespective of whether the pass-through entity distributes any of those profits to the owners. This disconnect creates the possibility of “phantom income”—taxable income without a…

On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act (the “Act”). The Act makes significant changes to federal tax law. As a result of these changes, your estate plan should be examined to determine whether your estate plan remains consistent with your dispositive intent…