Tag: Keith E. Phillis

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Buy, Sell, Pay Taxes: SCOTUS Decision Places Its Own Premium on Buy-Sell Insurance

All U.S. closely held businesses just received a warning from the highest court in the land that they should review their succession plans (or else risk a higher tax bill for the estates of their owners). On June 6, 2024, the Supreme Court of the United States (“SCOTUS”) issued its unanimous decision on Connelly v.…
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Decisions, Decisions: Choice of Entity vs. Choice of Tax Classification

Before forming any entity, founders need to make two fundamental decisions: which entity type is best for their business operations and which tax classification is best for the owners. Although the entity type and tax classification can be changed after formation, some forethought before forming a business can reduce expenses, taxes, and headaches. Choice of…
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New Domestic Content Adder Guidance: ‘Buy American’ is Back

On May 16, 2024, the Department of the Treasury and the IRS announced the release of Notice 2024-41,[1] which clarifies the safe harbor for classification of project components created in Notice 2023-38 and provides a new safe harbor for the domestic content bonus credit percentages for clean energy tax credits offered under the Inflation Reduction…
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Converting Office Space to Housing? There Are Incentives For That

With housing availability at record lows in many communities across the U.S., including gateway cities such as New York,[1] and commercial office space still not fully recovered from the COVID-19 pandemic,[2] the federal government is attempting to alleviate both issues by incentivizing the conversion of former office space to residential use.[3] The Biden Administration recently…
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What IRS’s Low-Income Adder Guidance Means For Renewables Projects

The Inflation Reduction Act of 2022 (the “Act”) breathed new life into the tax scheme for renewable energy projects, creating a new base tax credit with a series of adders that can significantly increase viability of projects that otherwise would not be economically feasible. The IRS issued Revenue Procedure 2023-27 (“Rev. Proc. 23-27”) on August…
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Potential Changes Threaten Estate Planning Strategies, Create Urgency to Act

Actor Will Rogers is widely credited with stating that “the only difference between death and taxes is that death doesn’t get worse every time Congress meets.” While most taxpayers fear tax laws changing for the worse, estate and gift taxation has only grown more favorable to taxpayers over the last decade despite very public opposition.…
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Location, Location, Location: Asset Protection for LLC Founders

A primary focus when starting a business should answer this question: What structure provides the most protection? New founders can get bogged down in the minutia about whether to choose a corporation or a limited liability company (“LLC”), how they want the business to be taxed, or what titles the owners should have. These are…
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