For years, the California Franchise Tax Board (FTB) has taken the position that trusts are subject to California state income tax on all of their California-source income, and that ...

On occasion, taxpayers holding investments in foreign financial assets or with foreign financial institutions may find themselves in the uncomfortable position of realizing that they have failed to ...

Editor: Albert B. Ellentuck, Esq. A gift qualifies for the annual gift tax exclusion ($14,000 for 2014) only if the transfer is of a present interest in the property. A present interest is defined as ...

Undocumented immigrants venture to the United States from all parts of the world and endure enormous challenges in their new life, ranging from cultural ones to those that are language–oriented in ...

Annually, millions of Americans are granted stock options by their employer. The majority of recipients are high-net-worth individuals (or soon will be). The positive impact of this wealth-creation ...

A corporation can deduct up to $5,000 of business startup costs under Sec. 195. The $5,000 deduction is reduced dollar for dollar (but not below zero) by the cumulative amount of startup costs ...

Sec. 1361 sets forth the basic qualifications for S corporation status. Among the most important are the limitation on types of shareholders and restrictions to a single class of stock. Tax Court ...

Planning with revocable trusts has become increasingly popular in recent years. In many instances, the motives for using a revocable trust are nontax and include avoiding probate, asset protection ...

A binding, nonjudicial settlement agreement, where available under state law, offers a practical alternative to a probate court ruling to revise a trust’s terms to comply with requirements to be a ...

The federal income taxation of gains (and losses) from the disposition of investments in collectible assets (collectibles) is relatively unfamiliar to many practitioners for several reasons. First, ...

The final regulations 1 issued by Treasury and the IRS to implement the advanced manufacturing investment credit (AMIC) include many taxpayer–friendly provisions. Found in Sec. 48D, the AMIC benefits ...

Individuals are subject to two income tax systems: the regular income tax and the alternative minimum tax (AMT). Taxpayers must compute their tax under each system and pay the greater of the two ...