Latest COST Conscious

ISSUE 24-25; December 13, 2024

Preparing for an Active 2025 – The softening of state revenues and the plethora of bills already prefiled for the 2025 session in many states indicate that 2025 will be a very active year for SALT legislation. Although 2024 was relatively quiet, there was some notable state legislation introduced that is likely to resurface in 2025. Which of the following would have the greatest negative impact on

Latest Legislative Alert

ISSUE 24-45; December 10, 2024

COST Supports Elimination of Remote Sales Transaction Threshold in New Jersey; COST Testifies at Texas Hearing on Proposed Amendments to Rule § 3.330

Latest Practitioner Connection

ISSUE 24-26; December 20, 2024

GeTin’ SALTy Episode 43: 2024 GeTin’ SALTy Year-End Wrap Up & Listener Appreciation Award – In this episode of GeTtin’ SALTy, host Nikki Dobay takes us back to some of our listeners' favorites and awards the inaugural Listener Appreciation Award! Nikki revisits highlights from some of the top podcast episodes of the year, which include snippets from episodes with Nancy Prosser [ Ep. 21], Alan Pase

BLOOMBERG TAX

US Congress Sends Spending Deal to Biden on Brink of Deadline

December 21, 2024

The Senate passed funding to keep the US operating until mid-March just after a midnight deadline, sending the bill to President Joe Biden for his signature. 

DOJ Unveils Long-Awaited Foreign Lobbying Disclosure Proposal

December 20, 2024

Exemptions to foreign lobbying transparency law that businesses and attorneys rely on to keep their advocacy for foreign interests under wraps would be revised under proposed rule changes the Justice Department unveiled Friday night.

US Sues to Stop Kentucky Man, Tax Firm, From Preparing Returns

December 20, 2024

The federal government alleges that Brandon Ross Williams and Refund HQ LLC engaged in fraudulent tax preparation practices resulting in understated tax liabilities and inflated refunds for customers, according to a recent lawsuit.

New York’s Congestion Pricing Plan Still Faces Legal Hurdles (1)

December 20, 2024

New York’s controversial program to start charging motorists entering parts of Manhattan next month could be derailed by a slew of legal challenges that are beginning to come to a head.

IRS PLR: Trust Distribution of Undivided Property Interest Not Preclude Being Held for Productive Use, Investment (IRC §1031)

December 20, 2024

The IRS has published a private letter ruling on Section 1031 determining that the distribution from a trust of an undivided Tenancy-In-Common (TIC) property interest, subject to a sales contract, as a result of the trust’s involuntary termination, to a taxpayer’s limited liability company, will be considered for federal income tax purposes as a distribution of the TIC Interest to the taxpayer, and will not preclude the TIC interest from being held for investment or for the productive use in a trade or business within the meaning of Section 1031(a). [PLR 202450007]

Georgia Partnership Contests IRS Denial of Conservation Easement

December 20, 2024

A Georgia partnership and its six business partners told the US Tax Court that the IRS was wrong to disallow a $6.26 million charitable conservation easement deduction on their land, whose "highest and best use" was a low-density residential development.

IRS PLR: Trust Distribution of Undivided Property Interest Not Preclude Being Held for Productive Use, Investment (IRC §1031)

December 20, 2024

The IRS has published a private letter ruling on Section 1031 determining that the distribution from a trust of an undivided Tenancy-In-Common (TIC) property interest, subject to a sales contract, as a result of the trust’s involuntary termination, to a taxpayer’s limited liability company, will be considered for federal income tax purposes as a distribution of the TIC Interest to the taxpayer, and will not preclude the TIC interest from being held for investment or for the productive use in a trade or business within the meaning of Section 1031(a). [PLR 202450005]

Musk Backs Johnson Plan to Avert Shutdown as House Vote Begins

December 20, 2024

Elon Musk, President-elect Donald Trump’s key adviser, backed House Speaker Mike Johnson’s third attempt at a spending package, boosting its odds as voting got underway late Friday. 

IRS PLR: Extension of Time Granted to Elect Out of GST Exemption Automatic Allocation Rules (IRC §2632)

December 20, 2024

The IRS has issued a private letter ruling on Section 2632 and Treasury Regulation 301.9100, granting taxpayer an extension of time to elect out of the generation-skipping transfer (GST) exemption automatic allocation rules, with respect to certain transfers made by taxpayer to a trust. [PLR 202451011]

IRS PLR: Extension Granted for Election Regarding Basis of Transferred Stock (IRC §362)

December 20, 2024

The IRS has published a private letter ruling on Section 362 and Treasury Regulation Sections 1.362 and 301.9100 granting an extension of time for a taxpayer to file a Section 362(e)(2)(C) Statement regarding a stock transfer, in the manner described in Treasury Regulation Section 1.362-4(d)(3), and filing the Section 362(e)(2)(C) Statement with an amended return for the taxable year in which the transfer occurred. The extension was conditioned on the federal tax liability of any relevant party not being lower, in the aggregate, for all years to which the Section 362(e)(2)(C) election applies, than it would have been if the Section 362(e)(2)(C) Statement had been timely filed, taking into account the time value of money. [PLR 202450011]