tax Archives

Apr 28, 2021

International Taxation of the Digital Economy: Can the OECD Unify Its Members?

As the global economy rapidly shifts and accelerates, the OECD has been focusing intently on developing and strengthening international tax rules in recent years. Back in February 2013, the OECD released a report addressing its concerns that existing international tax standards do not reflect an increasingly global economy, and more specifically, an ever-growing digital economy. The OECD is focused on answering two key questions that frequently come up: First, as multi-national enterprises (MNEs) make up a larger proportion of the global economy over time, and as more MNEs offer digital products and services to consumers worldwide, where is the value… Read more

Sep 30, 2019

IRS Finalizes Safe Harbor for Rental Real Estate Activities

On September 24, 2019, the Treasury Department finalized a safe harbor for rental real estate activities which should provide some tax benefits for lessors and investors. We addressed the draft safe harbor in a previous tax blog posting which can be found here. In this posting, we provide a summary of the final version of the safe harbor and recommendations for maximizing the benefits available under it. Background IRC Section 199A is a tax incentive for pass-through entities and sole proprietorships. It effectively reduces the federal tax rate on income arising from certain activities by as much as 20%. Thus, if… Read more

Sep 5, 2017

Beware of Post-Closing Actions Having a Retro-Active Pre-Closing Impact

We are now in September, and with the turn of the Gregorian calendar, comes the unofficial end of summer for both the United States and Israel. Most have taken their summer holidays, the children are back in school, and the company transaction environment gains new momentum for the balance of the calendar year. It is a good time to reflect. When selling the equity of a company, Sellers expect Buyers to require a representation and warranty that (1) all taxes of the company have been paid or reserved on the target’s balance sheet and (2) all tax returns previously filed… Read more

Nov 23, 2015

2016 Estate Planning Update

As soon as the last of the turkey is made into turkey soup, ‘tis the season to focus on year-end tax planning, particularly taking advantage of the gift tax annual exclusion. An individual can make gifts free of gift tax and without using any of his or her lifetime gift tax exemption of up to $14,000 per person per year. A married couple can make gifts of up to $28,000 per person per year regardless of which spouse actually makes the gift. (The annual exclusion amount is adjusted annually for inflation but will remain at $14,000 for 2016.) However, if… Read more

Sep 14, 2015

Lost and Found: Musings on the Tax Consequences of a Found Violin

Recently it was reported that Roman Totenberg’s Stradivarius was found 35 years after its suspected theft. The Stradivarius disappeared in 1980, believed by most to have been stolen. The violin surfaced this past June when an appraiser identified the Stradivarius as the missing violin. Eventually, Roman Totenberg’s daughters recovered the violin as his heirs. Mr. Totenberg died in 2012. Generally, it is not a taxable event when a property owner recovers stolen property. However, taxable income will be realized if the taxpayer took an income tax deduction for the theft loss. In such case, the value of the recovered property… Read more