November 06, 2024 | New York Law Journal
Alter Ego: Protecting Your Corporation's Tax StatusCreditors of corporate entities will, at various times, pursue the controlling shareholders to satisfy an undercapitalized corporation's indebtedness. Following along these lines, when it comes to income taxation, it is always important to be able to identify the proper taxpayer.
By Jeffrey A. Galant
8 minute read
September 27, 2024 | New York Law Journal
Deductibility of Promotional Expenses: Stock Car Racing?A discussion of the unique Tax Court case 'James W. Avery,' where, in connection with promoting his law practice, attorney James Avery attempted to deduct expenditures he incurred as a race car driver.
By Jeffrey A. Galant
7 minute read
August 28, 2024 | New York Law Journal
Caring for the Closely Held Business: Zeroing Out Profits"Adopting a decision structure which allows for consideration of an independent voice and credible comparability studies should go a long way to building the necessary record," writes Jeffrey A. Galant.
By Jeffrey A. Galant
8 minute read
July 03, 2024 | New York Law Journal
Planning Ahead for Tax LiabilitiesA noteworthy aspect of such planning, and the focus of this article, is the benefit, if any, of planning in advance for the relief from certain federal income tax liabilities potentially available to a married couple who reside together.
By Jeffrey A. Galant
11 minute read
May 10, 2024 | New York Law Journal
Great Expectancies: Anticipating InheritanceGiven their druthers, parents generally prefer to treat children equally when it comes to passing on parental property upon death however situations may exist where transfers can be fair and equitable, even though not in equal amounts or shares.
By Jeffrey A. Galant
9 minute read
April 05, 2024 | New York Law Journal
Constructive DeceitThe tools of intelligence (and counterintelligence) gathering, e.g., espionage, spying and the like, have been utilized since time immemorial by states, sovereign and otherwise, for both legitimate and nefarious reasons.
By Jeffrey A. Galant
7 minute read
January 26, 2024 | New York Law Journal
Family Business: A Missed Succession Planning OpportunityIn the annals of family business succession planning, this article discusses some clever, albeit flawed, attempts to transfer ownership interests in a mature enterprise to family members while avoiding the transfer tax toll.
By Jeffrey A. Galant
8 minute read
September 21, 2023 | New York Law Journal
What is the Deal? Proper Reporting Requires AnalysisSelling taxpayers often ignore or fail to appreciate the full picture of their sale transaction. This article examines two recent Tax Court cases in which taxpayers incorrectly accounted for the consideration received as sellers of property.
By Jeffrey A. Galant
6 minute read
August 21, 2023 | New York Law Journal
A Reminder That Partnership Tax Status Requires Business Purpose and Profit SharingLikely, either the partnership or limited liability company is the most flexible of entities now available for business- or investment-related ventures. Whether either such entity is a partnership for tax purposes is the subject of this note.
By Jeffrey A. Galant
7 minute read