Taxing Unrealized Appreciation On Lifetime Transfers And At Death

The Biden administration will propose a change in the tax-free basis step-up at death which has been a part of the tax law for a long period of time. Carter Ledyard’s first relationship with this subject occurred in 1970 when Richard B. Covey was contacted by the Trust Division of the American Bankers Association. In the Tax Reform Act of 1969, changes were made in the trust income tax laws relating to accumulation distributions […]

By | August 3rd, 2021 ||

California Passes “Workaround” To Federal Limit On State Tax Deduction For Certain Owners Of Pass-Through Entities

On July 16, 2021, Governor Newsom signed California Assembly Bill 150 into law, allowing certain owners of passthrough entities to find a way around the current $10,000 federal cap on state and local tax (SALT) deductions for individuals.  The new law, applicable to tax years beginning on or after January 1, 2021 and ending before January 1, 2026, allows for many partnerships, limited liability companies taxed as partnerships, and S-Corporations to pay an entity […]

By | August 2nd, 2021 ||

IRS Releases New COBRA Subsidy Guidance . . . With Less Than A Week Until Forms 941 Are Due!

On July 26, 2021, the IRS released Notice 2021-46 (the “Notice”), which provides new guidance on the 100% COBRA premium subsidies (the “Subsidies”) and the related tax credit under the American Rescue Plan Act of 2021 (March 11, 2021) (“ARP”).  The Notice supplements previous guidance provided under Notice 2021-31, and addresses additional issues.  See our previous alert for a detailed analysis of Notice 2021-31.

The Notice contains some unexpected surprises, which is unfortunate because plans and issuers have spent the past […]

By | July 29th, 2021 ||