Tax
Upstream Basis Planning — The Estate Planner’s Income Tax Planning Tool
This article revisits the upstream basis planning opportunity now enhanced by the enactment of the One Big Beautiful Bill Act....
When Old Laws Meet New Tech: Florida’s Uncertain Future in State Taxation
The last time Florida decided to be on the cutting edge of state taxes, it did not turn out so...
SCOTUS Brightens Constitutional Tax Lines Through Contrasting Judicial Perspectives
The U.S. Supreme Court ruled on three significant federal tax cases last year. The rulings significantly impact tax policy and...
Public Records and Taxpayer Confidentiality
The Florida Constitution establishes a mandate for open records laws and open meetings of public bodies making collegial decisions. This...
Twelve Angry Taxpayers: Why the Constitution Might Guarantee a Jury Trial for Accuracy and Fraud Penalties in Tax Cases After SEC v. Jarkesy
This article considers the current constitutional status of the Internal Revenue Code (I.R.C.) §6662 accuracy penalties and I.R.C. §6663 penalties...
Individual Retirement Accounts: What a Long, Strange Trip It’s Been
In the November/December 2019 issue of The Florida Bar Journal, I outlined individual retirement arrangement/account (IRA) basics and warned readers...
Federal Tax Lien Remedies
Federal Tax liens are rarely just “tax issues” and can impact clients in a multitude of ways across several practice...
Taxed by Design? Florida’s Tax on Interior Design Contracts and What To Do About It
Florida sales and use tax can be full of surprises. Generally, sales and use tax applies to the sale or...
Putting Carts Before Horses: Why the Taxpayer Failed in Connelly v. United States, and the Effect on Business Succession and Estate Tax Planning
On June 6, 2024, the Supreme Court unanimously ruled for the IRS in Connelly v. United States, 144 S. Ct....
FinCEN Fenced In? CTA Held Unconstitutional, but Filing To Continue
On March 1, 2024, the federal district court for the Northern District of Alabama issued a memorandum opinion, National Small...
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