Department of the Treasury Announces 2018 - 2019 Priority Guidance Plan

Following the enactment of Tax Reform, practitioners have been anxiously awaiting the announcement of the 2018-2019 Priority Guidance Plan to see what guidance has been prioritized.

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C Corporation vs. Pass-Through

The Rush to C Corporation that Wasn’t

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IRS’s Proposed Estate Tax “Clawback” Regulations

In November 2017, the IRS released proposed regulations clarifying the estate tax treatment of large lifetime gifts made now, while the federal estate and gift tax exemption is temporarily increased thanks to the Tax Cuts and Jobs Act of 2017.  These proposed regulations, if they go into effect as drafted, provide an opportunity for wealthy taxpayers to lock in the temporarily increased exemption by making large lifetime gifts.

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Current State of the Estate Tax: Sen. Elizabeth Warren’s Presidential Run and Tax Reform 2.0

In light of Sen. Elizabeth Warren’s (D-Mass) New Year’s Eve announcement that she is running for President, thus kicking off not only the new year, but also apparently the formal beginning of the Presidential campaign season, we thought it timely to consider the most recent estate tax proposal of Sen. Warren, and how it compares to the current state of the estate tax.   

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Parsing the Parking Pickle: IRS Issues New Guidance on Employee Parking UBIT

The IRS has issued preliminary guidance on an unexpected and controversial provision of the Tax Cuts and Jobs Act (the “Act”): a new UBIT tax on non-profit employee parking.

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