IRS Blocks SALT Cap Workarounds

Attempts to Circumvent $10,000 SALT Cap Blocked The U.S. Treasury Department recently issued a new regulation stating that taxpayers cannot claim that they made a charitable contribution if they received a state tax credit in exchange for a “gift” to a state fund. This rule effectively blocks state proposals aimed...

A Few Words on President Trump’s New Supreme Court Pick

Immediately following Justice Kennedy’s July 31, 2018 announcement of his retirement, Brett Kavanaugh, a prominent conservative D.C. Circuit Court judge, received a call from the President. This marks Donald Trump’s second opportunity to appoint a Supreme Court Justice. Since his nomination on July 9, 2018, Kavanaugh has been the subject...

The Colliot Case, Part II: $100,000 Limit on Civil FBAR Penalties

In Part I, we discussed a very significant case involving a taxpayer who willfully failed to file FBARs for a number of years. Mr. Dominique Colliot objected to the extraordinary penalties assessed against him, arguing that 31 CFR 1010.820(g)(2) , the federal regulation used by the IRS to justify its...

First Steps to Establishing Your New Business: Choosing the Right Business Structure for You, Part II

In Part I, we described four types of business structures: informally structured sole proprietorships and general partnerships, and two common corporate entities (S Corporations and C Corporations) that provide their owners and managers with limited liability. Aside from “S” or “C” corporations, what other business entities offer limited liability? The...

First Steps to Establishing Your New Business: Choosing the Right Business Structure for You, Part I

Turning your business idea into reality can be exciting and gratifying. Before you get started, however, you need to decide how your new venture will be structured. Your choice will determine how your business is owned, operated and taxed. The structure you choose will also determine your potential personal liability...

California’s Attempts to Circumvent the New Tax Law’s SALT Limitation

Reports indicate that low-income and middle-class Californians are fleeing the state – most are relocating to Arizona, Nevada, and Texas. The reason? Housing costs and high taxes. The new tax law hasn’t necessarily helped wealthy California homeowners, either. For one thing, the Tax Cuts and Jobs Act (TCJA) capped their...

$125,000 State Tax Problem Fixed by Correcting Previous Years’ Tax Returns

A Moskowitz LLP Success Story A business owner came to us after receiving a Franchise Tax Board (FTB) Notice. The Notice stated that the FTB was disallowing a $1,204,541 million corporate loan to shareholder, and consequently assessed $125,197 in additional state income taxes. There is a long history of IRS...