Tag: Michael J. Raposa

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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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1031 Exchanges and the Complexities of Seller Financing

With interest rates nearly the highest they’ve been in decades, but property prices still high, sellers and buyers are looking for ways to finance real estate transactions while also availing themselves of IRC § 1031’s non-recognition of taxable gains in like-kind exchanges (“1031 Exchanges”). When considering options such as seller financing in 1031 Exchanges, both…
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The Brass Tacks: IRS Creates Process for Withdrawing ERC Claims

The Internal Revenue Service (“IRS”) recently granted employers a means to avoid interest and penalties on inappropriately taken Employee Retention Tax Credit (“ERC”) claims.[1] This surely will come as a relief to taxpayers who are (or were) concerned that they may have mistakenly claimed ERCs for tax years 2020-2022. As we detailed in our last…
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Gun Trusts in Estate Planning: No Time To Be Quick on the Trigger

When considering an estate plan, clients who own firearms should remember that very often, their firearms require special consideration and planning, particularly given the intricacies of federal, state, and local gun laws and regulations. Gun trusts are a common mechanism for ensuring ease of ownership and inheritance of certain types of firearms and other weapons…
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How IRS Is Cracking Down on Employee Retention Tax Credit Fraud

The Internal Revenue Service (“IRS”) has recently devoted great attention to detecting, investigating, and prosecuting fraud, particularly as it relates to the Employee Retention Tax Credit (“ERC”) post-COVID. On a webinar broadcast on July 25, 2023, hosted by the IRS’s Office of Fraud Enforcement and National Fraud Counsel, the presenters noted that ERC claims top…
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WHAT IF ARTIFICIAL INTELLIGENCE & MACHINE LEARNING MEAN THAT SKYNET IS YOUR HOSPITAL’S NEXT ELECTRONIC HEALTH RECORD

Imagine a hospital emergency room ten years from now. Sam Brown, a car crash-victim, has come in with severe, life-threatening injuries. ER admissions staff enter Sam’s information into the hospital’s artificial intelligence (AI)-enhanced electronic health record (EHR) system. From this point forward, every medical device that interacts with the patient (e.g., vital signs monitors, surgical…
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