Ashley Thompson

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Possible Congressional Action May Undercut Proposed 2704 Regulations

By Ashley Thompson on October 3, 2016 Posted in Family Business

Republicans in the House of Representatives and the Senate have introduced bills to derail the Proposed Regulations under Section 2704 of the Internal Revenue Code (“Proposed Regulations”), including bills to (1) nullify the Proposed Regulations and prevent future regulations, and (2) cut federal funding associated with the enforcement of such Proposed Regulations. The first bill, … Continue Reading

What do Prince, Michael Jackson, and Whitney Houston Have in Common?

By Ashley Thompson on July 12, 2016 Posted in Estate Tax

Michael Jackson, Prince and Whitney Houston each revolutionized the music industry and impacted popular music for decades. We all appreciate how Michael Jackson moonwalked across the stage, Prince made it (purple) rain and Whitney Houston will always love you. These impactful artists changed, and continue to change, the music landscape. What do Michael Jackson, Whitney … Continue Reading

The Three Most Important Provisions for S Corporations Under PATH Act

By Ashley Thompson on January 21, 2016 Posted in Tax

It has become a tradition that at the end of each year, Congress passes legislation to extend previous legislation. In late 2015, Congress passed Public Law 114-113, which contains the Protecting Americans from Tax Hikes Act (“PATH”). PATH’s benefits to donors and charities were detailed in a previous post, which is available here: Donors and … Continue Reading

Estate Planning Considerations for Millennials

By Ashley Thompson on November 17, 2015 Posted in Estate Planning

I am a millennial. I grew up in the age of the Internet, computers, and text messaging. I had my first cell phone in late elementary school, where I mastered the game of Snake on a one-inch square screen. My generation then progressed past dial-up Internet, Game Boy, and CD players to smartphones, apps, and … Continue Reading

Bitcoin and the Like: Further Tax Developments to Monitor

By Ashley Thompson on May 13, 2015 Posted in Digital Assets, Virtual Currency

Virtual currency developments continue to emerge, including state tax guidance, a court decision on deductibility of losses, and the Uniform Fiduciary Access to Digital Assets Act (the “Act”). State Tax Guidance The New Jersey Division of Taxation released Technical Advice Memorandum 2015-1 (the “NJ TAM”). The NJ TAM explains New Jersey’s treatment of virtual currency; … Continue Reading

Bitcoin and the Like: Tax Considerations

By Ashley Thompson on April 1, 2015 Posted in Tax, Virtual Currency

Virtual currency is a new, untested, and unregulated asset. The Internal Revenue Service (IRS) defines “virtual currency” as a digital representation of value that functions as a medium of exchange, a unit of account, and/or a store of value. “Convertible virtual currency” is virtual currency that has an equivalent value in real currency, or acts … Continue Reading

IRS Attempts to Simplify the Application Process for Certain 501(c)(3) Organizations, but is “EZ” Better?

By William J. Culbertson and Ashley Thompson on October 31, 2014 Posted in Tax

On July 1, 2014, the Internal Revenue Service (“IRS”) released Form 1023-EZ, Streamlined Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code (“Code”). Form 1023-EZ is an abbreviated version of the twelve page Form 1023 (which can be supplemented by as many as seven schedules) and is intended to streamline the … Continue Reading

CRESCENT HOLDINGS: An Issue of First Impression for Partners with Capital Interests

By Ashley Thompson and Theodore Gelt on January 16, 2014 Posted in Income Tax, Tax

On December 2, 2013, the United States Tax Court issued an opinion in Crescent Holdings, LLC v. Commissioner, 141 T.C. No. 15. This opinion affects individuals who receive a non-vested capital interest in a partnership. In what it states was an issue of first impression, the Tax Court held that income of the partnership that … Continue Reading