Larry's Tax Law

2024 is almost at an end.  For me, this year went by at lightning speed.   

2024 was a wonderful year, full of change and opportunities.  I continue to be extremely grateful for the unwavering support of my family, friends, clients and law colleagues! 

Mark Twain is accredited with saying:

“Twenty years from now you will be more disappointed by the things that you didn’t do than by the ones you did do, so throw off the bowlines, sail away from safe harbor, catch the trade winds in your sails.  Explore, Dream, Discover.”

During 2024, I followed Mark Twain’s mantra – I threw off the bowlines and sailed my ship away from the safety of the harbor, catching the trade winds! 

The Tax Reform Act of 1986 (the “TRA 86”) was signed into law by President Ronald Reagan on October 22, 1986, exactly 38 years ago today.  TRA 86 was sponsored by, among others, Representative Richard Gephardt (D-Missouri) in the U.S. House of Representatives and Senator Bill Bradley (D-New Jersey) in the U.S. Senate.  It was strongly supported by the Chairman of the House Ways and Means Committee, Dan Rostenkowski (D-Illinois) and the Chairman of the Senate Finance Committee, Bob Packwood (R-Oregon). 

TRA 86 is one of the most comprehensive pieces of tax reform legislation ever enacted in the United States.  It was the result of a collaborative effort by Democrats and Republicans that spanned three years.

I am excited to share that the 83rd Institute on Federal Taxation (IFT) will be held in New York City on October 20-25, 2024, and in San Diego, California on November 17-22, 2024.

This year, I will present my latest white paper, “A Magical Mystery Tour Through Subchapter S – A Look At Some Of The Twists and Turns.”  During our session, we will take a deep dive into some of the interesting, yet deceptive and/or obscure, provisions of Subchapter S that could catch the unwary off guard.  Our tour will take us on a journey through some of the treacherous terrain containing the built-in gains tax, shareholder eligibility, the impact of excessive passive income on S corporations with C E&P and the impact of a fraudulent S corporation return on the shareholders, and we will end our journey frolicking through the beauty created by some interesting cases and rulings.

I have been sharing knowledge with tax professionals through writing papers and articles, and presenting at tax conferences for almost 40 years.  On March 11, 2013, with the encouragement of others, I entered the digital publishing age, embarking on a new journey with the launch of Larry’s Tax Law.  At that time, I was unsure where the journey would take me.  My goal was simple and straightforward – to continue sharing knowledge about highly relevant and interesting tax law matters and developments with accountants, tax attorneys and other tax professionals.  

Larry’s Tax Law is now more than a decade old.  To be more precise (as we tax professionals tend to be), the blog is now 11 years, 1 month and 14 days old.  We have been sharing knowledge with tax professionals in this digital format for more than 4,063 days!

For so many of us, 2023 has been a difficult year.  The so-called end of the COVID-19 pandemic looked to be a bright spot in our lives, but with wars raging in Ukraine and Gaza and dramatic social unrest at our doors, we continue to face difficult times.

I am extremely grateful for the unwavering support of family, friends, clients, and my law colleagues, especially in these troubling times!

During these trying times, we have had to be mindful of the good that surrounds us.  As the Ancient Greek philosopher Aristotle is accredited with saying:

“It is during our darkest moments that we must focus to see the light.”

During 2023, I was able to speak in person at several tax conferences.  It was wonderful to actually see and visit with conference attendees rather than delivering a lecture into a computer screen’s virtual abyss.  This year, I was fortunate to have the opportunity to speak at the following tax conferences:

The 82nd Institute on Federal Taxation (IFT) will be held in New York City on October 22-27, 2023, and in Berkeley, California, on November 12-17, 2023.

This year, I will be presenting my latest white paper, “A Journey Through Subchapter S / A Review of the Not So Obvious & The Many Traps That Exist for the Unwary.”  Our discussion will examine the potpourri of issues arising from Subchapter S that may not be readily apparent to the tax practitioner, such as matters arising from the single class of stock requirement, the built-in-gains tax, the interplay between Subchapter C and Subchapter S, lingering E&P, and late (or never made) elections.  The session will also alert tax practitioners to traps that exist for the unwary and, in some cases, possible ways to avoid or remedy falling into one of these traps.

I am pleased to announce that I will be presenting at the 49^th Annual Notre Dame Tax & Estate Planning Institute in South Bend, Indiana.  The Institute this year will occur on September 20-22. 

I will be presenting my white paper "Entity Classification – The Check-The-Box Regulations Revisited."  My discussion will cover recent developments in the law relating to entity classification, limitations under the check-the-box regulations, flexibility and planning opportunities created by the regulations, traps that exist for the unwary, and practical planning strategies for tax advisers.

I am extremely grateful to have the opportunity to speak at the Notre Dame Tax & Estate Planning Institute and present among a tremendous panel of speakers, including Jerry Hesch, Paul Lee, Jonathan Blattmachr and Stephen Breitstone.  It looks to be a terrific program for income tax and estate tax attorneys.

View the complete agenda and register using the link to attend the institute in person or to obtain the audio recording and the materials.

2022, like the prior two years, has been difficult.  The COVID-19 pandemic and social unrest continues to be at the forefront of our existence.  On top of that, inflation and possible recessionary times are among us.

Thanks to the unwavering support of family, friends, clients, and colleagues, we are enduring through these turbulent times.  I am so grateful for these relationships!

I have had to constantly be mindful of the good things going on around us.  As American Poet Walt Whitman is accredited with saying:

The NYU 81st Institute on Federal Taxation (IFT) returns to in-person programming this year in New York City on October 23-28, 2022, and in San Diego on November 13-18, 2022. 

This year, I will be presenting my white paper “Entity Classification – The Check-The-Box Regulations Revisited."  Our discussion will cover recent developments in the law relating to entity classification, limitations under the check-the-box regulations, flexibility and planning opportunities created by the regulations, traps that exist for the unwary, and practical planning opportunities for tax advisers.

I am extremely grateful to have had the opportunity to present with IFT for more than a decade. During this year’s Institute, I will again be presenting as part of the Closely-Held Business program, chaired by my esteemed colleague Jerry David August, on the mornings of October 27 (NYC) and November 17 (San Diego). 

Like last year, 2021 has been a difficult year.  The COVID-19 pandemic continues to be at the forefront of everyone’s existence.  On top of that, the Delta variant and the most recently discovered Omicron variant have entered the picture.

Personal loss, social unrest, lofty economic hurdles and limitations on personal interaction have permeated the planet for almost 24 months.  For at least the foreseeable future, it appears these strained conditions will continue.    

Thanks to the steadfast support of family, friends, clients and business colleagues, we are persevering throughout these trying times.  I am so grateful for these relationships!