Most Recent Posts
On The Bitterness Of The Gender War
Two of my Forbes pieces - Lesbians Want A Church of Their Own and Why Gender-Critical Radical Feminists Might Want A Church And Why IRS Approved - which broke out of...
You Can’t Get Tax Advice From Your Spirit Guide
Things did not go well for Christopher Dufresne, son of famous psychic Sylvia Browne and himself a psychic, in the Tax Court decision that came out last week. Judge Kerrigan confirmed the IRS notices of deficiencies of over $500,000 and accuracy penalties that tack on another hundred thousand plus. You would have thought that he would have seen it coming, but that is not how it works according to his book.
Gender War – Dummy Guide – Where To Begin
There is no wholly masculine man, no purely feminine woman. - Margaret Fuller Top rated guide so far What I believe about sex and gender (and what I don't) by...
Voraciousness Of The New York Income Tax And The Jersey City Solution
So you live in Agony, but you work and own a business in Ecstasy. Ecstasy gets to tax you on what you earn there. Agony will give you a credit for those taxes to Ecstasy. The credit will generally be the lesser of what you paid Ecstasy or what Agony taxed you on that income. If Ecstasy has a lower rate than Agony, it is a wash. If Ecstasy has a higher rate, you are out of pocket the difference.
It is simple and fair. If the states have the same rate, the one where you live ends up getting the tax on your income from investment and the like and the state where you work gets to tax your income from working. It’s good enough for Agony and Ecstasy, but not for New York and the growing number of states that follow the “New York rule”.
How Tax Reform Is Like Gun Control
I think the lesson is that we all should get out of our bubbles more. If you are in favor of very strict gun control, you will probably learn more useful things by talking to gun enthusiasts and reading their magazines. Same principle if you are interested in getting the wealthy to pay more taxes. You might also find that your notions of what people who disagree with you actually think are different from what you project.
How Wealth Accumulators Can Use Trusts To Avoid State Income Tax
When you are talking about large wealth, there are of course a great number of non-tax considerations, but I’m not going to be able to help you much there. Other than to tell you based on what I have observed through my career it is about fifty-fifty whether inheritance is good or bad for people, which is a little demoralizing for estate planning.
As to the lawyers who work on these issues, I would observe that there is a danger that they can get into ruts. They may be attached to the state that they practice in. Clearly, that narrows your option. Also planning in this area tends to be focused on transfer taxes which is really big money for large estates, but not something that happens every year. Income tax planning can get short shrift sometimes or the income tax implications of estate planning techniques can be overlooked.
CPA Sinks Under Millions In Aiding And Abetting Penalties On Mariners Deductions
The problem with the position that Kapp was recommending and using in preparing returns and schedules for returns not prepared by him, is that he was using the rate specified for meals and incidentals, which is about ten times the rate for just incidentals. You see Johnson was just a partial victory. A nonitinerant sailor is “away from home” when onboard, but only entitled to the much lower incidental per-diem, because the owners of ships have an apparently universal practice of feeding their sailors.
Joe Biden’s Tax Returns – No Reason Democrats Need To Overpay Their Taxes
You will find case law about taxpayers having income recharacterized because of low S corporation salaries, but I do not think that there are any such cases where the taxpayers were taking six-figure salaries. The reason for this is probably that there are a lot of C corporation cases where taxpayers are hit for taking salaries that are too high. A recent example was Dr. Afzal Ahmed, who wiped out $2.78 million in profit by taking a bonus. The IRS disallowed a million of the bonus.
As Rubin notes in his article Newt Gingrich was also criticized for using this technique, and I stood up for him too.
Florida Man Blows IRA Bankruptcy Protection
The facts, in this case, were pretty egregious. Will bankruptcy trustees start scrutinizing plan operations closely in order to find some foot fault that would disqualify them? Self-directed IRAs have always made me a little nervous and I find it a little shocking that the transactions described in this decision would not have set off alarm bells at the custodian. I’m thinking there might be a bigger story there.
The practical takeaway I get from the decision is that if you have reason to be concerned about asset protection, you might want to think about whether a self-directed IRA is your best choice since apparently, it is not just the IRS you have to worry about looking over your shoulder.
Clever Techniques To Defer Capital Gains – Maybe Too Clever
This is the technique that is most exciting Using an installment obligation as collateral will generally trigger gain recognition. The Monetized Installment Sale (MIS) purports to work around this allowing you to have the overwhelming bulk of the proceeds available for whatever purpose you want, while still deferring gain.
The support for this technique comes from a 2012 advisory letter from the IRS Chief Counsel Office – 20123401F . It’s important to note that this letter is not a blessing of the transaction. The revenue agent was asking whether the transaction should be attacked with either “substance over form” or “step transaction”. The Associate Chief Counsel told the revenue agent that it should not. So the answer was not that the taxpayers are right, just that they are not wrong in those particular ways.