• The Straight Dope on SALT Workarounds

    The Tax Cuts and Jobs Act of 2017 (the "TCJA") brought about sweeping changes to the Internal Revenue Code. One of those changes was a $10,000-per-tax-return cap on the deduction for state and local income, sales, and property taxes ("SALT") not incurred in running a trade or business (this includes any...

  • The New Partnership Audit Rules Are Coming!

    For the corporate attorneys and accountants who read the headline and asked, "What audit rules?," you may want to pay especially close attention. What's All the Fuss About? With the Bipartisan Budget Act of 2015 (BBA), Congress repealed the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA). Why is this important? TEFRA...

  • Speculating About Tax Reform

    I saw the hashtag #UStaxreform trending on LinkedIn and figured now is as good a time as any to add to the conversation about where the future of the U.S. tax system might be headed. Many have already weighed in on the subject, with my favorite perspective coming from the brilliant...

  • Media Reporting on the American Tax System - Don't Believe What You Hear

    With the recent revelation of parts of Donald Trump's 1995 tax returns, the media and some other commentators seem to be up in arms about his over $900 million in business losses being some kind of "loophole." Folks - that is not a loophole. Mr. Trump received approximately $450 million in tax savings...

  • Extended Thoughts on the IRC 2704 Proposed Regulations

    In the wake of the Internal Revenue Service releasing Proposed Regulations pertaining to IRC 2704 yesterday, I have received many questions and conducted many discussions about the Proposed Regulations' content and potential impact.  I posted a short status update about my preliminary thoughts yesterday and would like to expand on those thoughts with...