3defense
George F Wil...360x1000
2theleastofus
6confidencegames
James Gould Cozzens 360x1000
Anthony McCann2 360x1000
13albion
299
Edmund Burke 360x1000
Mark V Holmes 360x1000
1falsewitness
1confidencegames
1madoff
Margaret Fuller4 360x1000
199
2lookingforthegoodwar
2jesusandjohnwayne
Margaret Fuller1 360x1000
Thomas Piketty2 360x1000
1theleasofus
Thomas Piketty1 360x1000
Gilgamesh 360x1000
3albion
Margaret Fuller 360x1000
Learned Hand 360x1000
Samuel Johnson 360x1000
2paradise
1albion
2transadentilist
499
AlexRosenberg
Susie King Taylor2 360x1000
8albion'
4albion
12albion
2gucci
Brendan Beehan 360x1000
George M Cohan and Lerarned Hand 360x1000
9albion
11632
4confidencegames
Spottswood William Robinson 360x1000
1trap
lifeinmiddlemarch1
Storyparadox1
6albion
Anthony McCann1 360x1000
2trap
2defense
lifeinmiddlemarch2
399
Tad Friend 360x1000
10abion
1gucci
LillianFaderman
Stormy Daniels 360x1000
Lafayette and Jefferson 360x1000
3paradise
Maria Popova 360x1000
storyparadox3
Adam Gopnik 360x1000
1paradide
1jesusandjohnwayne
3confidencegames
2confidencegames
Margaret Fuller 2 360x1000
2lafayette
3theleastofus
Maurice B Foley 360x1000
1defense
Susie King Taylor 360x1000
1lafayette
Office of Chief Counsel 360x1000
7albion
Ruth Bader Ginsburg 360x1000
5albion
1lauber
1lookingforthegoodwar
14albion
Richard Posner 360x1000
Margaret Fuller2 360x1000
2falsewitness
storyparadox2
11albion
7confidencegames
5confidencegames
Betty Friedan 360x1000
2albion
Margaret Fuller3 360x1000
Margaret Fuller5 360x1000
1empireofpain
Mary Ann Evans 360x1000
Thomas Piketty3 360x1000
1transcendentalist
Joint Extension Payments

Joint Extension Payments

It’s not unusual for family businesses or trusts to make estimated tax payments for beneficiaries or family owners.  Controllers or trustees charged with that responsibility would be prudent to make those payments as individual, not joint, estimated tax payments.  Whoever was making the payments on behalf of Sarah Crane (Angus MacPhail’s ex-spouse) probably wishes they had followed that course.

read more
Short Note on Purging Earnings and Profits

Short Note on Purging Earnings and Profits

I recently wrote on a strategy for old C corporations with appreciated properties. The idea is to make an S election and wait out the built-in gains period. Among the provisions of the Jobs Act which just passed the House and is now awaiting signature is a shortening of the period to five years. This is a lot less than 10, but it is still greater than 3. So a corporation that cannot rely on having active income will still want to purge its earnings and profits before the favorable rate on dividends goes away. The shortening of the recognition period makes this strategy much more viable.

read more

Over and over again courts have said that there is nothing sinister in so arranging one’s affairs as to keep taxes as low as possible. Everybody does so, rich or poor; and all do right, for nobody owes any public duty to pay more than the law demands: taxes are enforced exactions, not voluntary contributions. To demand more in the name of morals is mere cant.