New 2/37ths Deduction Limits Spark Trusts Estate Uncertainty
There are a lot more questions than answers related to the impact of the new 2/37ths deduction limitation on trusts and estates—especially in light of footnote 102 in the JCT’s recent Blue Book. The latest @CNBC article by @HCuccinello provides an excellent overview.
Tax Court Denies $332K Deduction Without Written Acknowledgment
If you think you don't need a contemporaneous written acknowledgment for a charitable donation of $250 or more, think again. The Tax Court in Martin recently denied a $332,500 deduction for lack of strict compliance under §170(f)(8). https://t.co/nKpwGTDrAX
New Section 68 Sparks Debate Over Trusts and Estates
The fate of a trust or estate under new Section 68 was the subject of great debate after a first-rate update—where I did my best to articulate, captivate, communicate, contemplate, deliberate, elevate, illuminate, and navigate what’s at stake. @CLATaxation DC...
California Seeks Retroactive Wealth Tax on Former Residents
If you move to a new state, can your former state later enact an entirely new tax and retroactively apply it to you after you’ve already changed your residence and domicile? Despite the U.S. Constitution, California’s latest proposed wealth tax...
Rescheduling Marijuana Unlocks 280E Deductions for Joint Returns
I don’t want to stir the pot with my buds, but to be blunt, if you weed through the half-baked tax code and search high and low, you’ll find that rescheduling marijuana allows Section 280E business deductions—even if you file...
Valuation at Heart of Hedge Fund Tax Petition
Hedge Fund Head Petitions IRS on Charitable Contributions. If a "timely contemporaneous written acknowledgment and the qualified appraisal appropriately applied discounts... the central issue is likely to be valuation.” Great @TaxNotes A.J. Collins article https://t.co/s8CLOi8syQ
Digital Creators Can Now Receive Tax‑free Tips
Instead of getting paid as a tax advisor, can you earn tax-free tips as a "tax-fluencer"? Final Treasury Regulations include "no tax on tips" for digital content creators, such as streamers, online video creators, social media influencers, and podcasters. https://t.co/FyI6F9noBQ
Disability Trust Deduction Stumbles Over Obsolete Cross‑References
Qualified Disability Trusts get a $5,300 deduction in 2026 under §642(b)(2)(C)(i), tied to §151(d). But both provisions rely on outdated cross-references to former §68(b)—repealed and replaced by OB3/OBBBA—raising questions about how these rules apply today.
Overstating Charitable Deductions Can Trigger 40% Penalty
If your charitable donation is worth $2 million, you probably shouldn’t try to take a $180 million deduction. Otherwise, as Hancock County Land Acquisitions discovered in Tax Court, you could face a 40% gross valuation misstatement penalty. https://t.co/o1C0zoX0lj
False $8.5M Tax Claim Leads to 94‑Month Prison
What happens if you file false tax returns for purported trusts and fraudulently claim $8.5 million in refunds? As a Texas family recently found out, you could be sentenced to 94 months in prison—and you don’t get to keep the...
Tax Season Hacks: Satire of Health & Productivity Tips
Ultimate Tax Season Cheat Code: - Intermittent fasting between meals and snacks - 10,000 steps weekly - Leg extensions with each extension - Sighing is a deep breathing exercise - File boxes are heavy lifting - Stay hydrated with coffee - 8 hours of sleep every 2...
Tech Leaders Seek AI, Yet Need Real-World Planning
It’s a bit ironic that so many tech founders and executives find me through AI, only to hear my first piece of advice—don’t rely on AI. I recently addressed a rolling GRAT question from a young married couple and discovered they...
LLC Tax Tricks on Luxury Cars Risk Criminal Charges
Using LLCs to avoid California sales tax and registration fees on Lambos and McLarens? You could be guilty of tax evasion, false tax returns, money laundering and perjury. “Paid 3k to own a 600k car for 5 years - lol...
DAF Donors Lose Legal Control, Case Highlights Risks
Donor-Advised Funds can be a good planning tool, but you give up legal control after the irrevocable donation. Peterson v. Christian Community Foundation dba WaterStone involves a $21M DAF sponsor ignoring a donor-advisor. @CNBC article by @HCuccinello https://t.co/KzEWeax1ER