CURRENT EDITION

State Tax Planning with the “80/20 Company” Exclusion
Many multinational groups find that foreign-source dividends and other income earned by domestic affiliates are fully or partially subject to state income taxation, even where the federal system provides an exemption. This state-level “leakage” can be material – particularly in high-tax jurisdictions – and is often overlooked because the income appears sheltered at the federal level. For groups with predominantly foreign operations, a starting structure or a restructuring that causes one or more domestic affiliates to qualify as an “80/20 company” can substantially reduce or eliminate state taxation on that income.
READ MOREIf You Have an IRS Audit Coming Up, Make Sure You Have the Tax Law on Your Side
When you have to go toe-to-toe with the IRS, make sure you keep the fight clean. The only way to succeed when arguing your case with an auditor is to follow the IRS’s own procedures. And, the primary way to do that is—you guessed it—keeping proper documentation. With this article, you’ll better understand where tax authority is derived, what rules the IRS must stick to, and what rules the IRS accepts.
Read MoreA Tax-Season “Cheat Sheet” to Avoid Getting Cheated
Scams lurk around every corner year-round, but tax time is when they seem to flourish. The crooks that come out to swipe cash, credit card info, Social Security numbers and other personal details are nothing if not innovative, always ready to use any tech advancement, disaster headline or snake-oil sales tactic to worm their way into people’s wallets. Part of your role these days as a financial pro is to help protect clients against these cons. Here’s the latest to know.
Read MoreTAX COURT ROUNDUP – March 2025
February brings us Groundhog Day, but there are always new developments in Tax Court, as well as refreshers to keep practitioners current.
Read MoreRenewable Energy Tax Credits: An Opportunity to Sustainably Optimize Taxes
Investment Tax Credits (“ITCs”) and Production Tax Credits (“PTCs”, and together with ITCs, “RETCs”) have existed for decades and reflect the U.S. government’s commitment to incentivizing clean energy solutions in industry and commerce. The availability of RETCs was most recently extended by the Inflation Reduction Act of 2022 (“IRA”), which fundamentally transformed policy in this space by tying such credits’ expiration to the U.S. reaching certain targets for greenhouse gas reductions. While the recent change in Executive Branch leadership casts doubt over the longevity of RETCs, a full repeal seems unlikely given the scope and scale of domestic projects which utilize and benefit from such credits. This article discusses how RETCs may benefit both buyers and sellers in an increasingly uncertain environment.
Read MoreDeFi-nitely Confusing: Final Regulations for Digital Asset DeFi Brokers
Well, at least the treasury department is true to form. They have ruined yet another international trip for me, which is the third time if you’re keeping track at home. This time it was a weekend trip to Toronto, which coming from upstate New York is technically “international,” yet somehow substantially closer to home than New York City. Late afternoon on the Friday before New Year’s Eve, the Treasury released another 115 pages of Digital Asset Regulations, along with a 13 page notice for good measure. As we’ve discussed previously on TOTTB, the last set of regs punted on a number of more complex crypto issues. This most recent release is all about one of those issues, Decentralized Finance, better known as “DeFi.”
Read MorePig Butchering Can Slaughter Your Clients’ Finances
People use the online space to look for love, make business and financial decisions. And all of these decisions can have serious tax implications. That is why as trusted financial and tax advisors, it is important for us to be aware so we can help protect our clients. In 2024, the Federal Trade Commission released a report showing consumers reported losing $4.6 billion in investment scams. That's only the amount reported, so our clients are at risk if they are online making financial decisions. Today, let's look at a newer player in the online investment scam arena: pig butchering. If you're like me, you're probably thinking “what in the world does this have to do with taxes?” Unfortunately, everything. It leads to taxpayers receiving tax bills for money they withdrew but lost as victims of theft.
Read MorePinterest for Accountants: Curating Inspiring Financial Resources and Building Brand Awareness
As we continue our series of articles on various social media platforms, we will focus on Pinterest. As discussed, social media is an indispensable tool for professionals across multiple industries. Accountants, often perceived as traditional and reserved, can harness the power of these platforms to extend their reach, engage with clients, and establish a solid online presence. Pinterest is known for its easy visuals and use, offering unique opportunities for us accountants to curate boards with valuable financial resources. By strategically using Pinterest, we can attract and engage our target audience, drive website traffic, and build brand awareness.
Read MoreLeaving the United States, Part III: Dual Citizenship
In Part I of this three-part series, we discussed the implications and taxes for American expatriates. In Part II we turned our attention to renouncing citizenship. Here in Part III, we will consider the halfway point of dual citizenship. And as you would expect, taxes are a serious consideration.
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CURRENT EDITION

State Tax Planning with the “80/20 Company” Exclusion
Many multinational groups find that foreign-source dividends and other income earned by domestic affiliates are fully or partially subject to state income taxation, even where the federal system provides an exemption. This state-level “leakage” can be material – particularly in high-tax jurisdictions – and is often overlooked because the income appears sheltered at the federal level. For groups with predominantly foreign operations, a starting structure or a restructuring that causes one or more domestic affiliates to qualify as an “80/20 company” can substantially reduce or eliminate state taxation on that income.

Real World Ethics: What Happens When a Judge Doesn’t Understand Tax Law
We all know how messy tax returns can get when couples who used to file jointly divorce and there are children (and tax credits) involved. It’s often difficult to explain the rules surrounding Head of Household filing status and the various tax credits available to parent-clients who have separated or divorced. But what happens when the clients misunderstand and decide to fight about it in family or divorce court? The following case study says “nothing good” can be a horrifying and frustrating answer to this question.

The Return of Taxable Student Loan Forgiveness: Planning Considerations for 2026 and Beyond
Remember the dreaded student loan “tax bomb?” For the past few years, it’s been easy to forget about it. Thanks to a temporary federal tax exclusion enacted during the pandemic, borrowers who received student loan forgiveness between 2021 and 2025 generally didn’t have to include that forgiven debt in their taxable income — leaving many borrowers (and their advisors) to wonder if the tax bomb would eventually disappear for good. Unfortunately, Congress allowed the temporary exclusion to expire. Beginning in 2026, forgiven student loan balances may once again be treated as taxable income. While that sounds like a major change, the reality is that most borrowers didn’t benefit from these tax-free years in the first place. For most borrowers, forgiveness is still years away, and there’s no crystal ball for what future federal policymakers may do. In the meantime, advisors may need to revisit planning conversations that many assumed were behind them. And depending on where a borrower lives, their federal tax bill may be only part of the story.








