Excluding Gain on the Sale of Your Principal Residence

Income Tax, Tax

Under IRC §121, gain on the sale of a principal residence of up to $250,000 (or $500,000 for spouses, see below) may be excluded from gross income. This may seem pretty straightforward, and many times it is, but it also has numerous requirements in order to apply, as well as numerous exceptions that may apply.…
Read More

Tax Effect of Protocol Updates to Blockchain-Based Cryptocurrency

Chief Counsel Advice, Cryptocurrency, Income Tax, Regulatory

A recent Chief Counsel Advice Memorandum (“CCA”) discusses certain tax consequences pertaining to a taxpayer owning cryptocurrency native to a blockchain that undergoes a protocol upgrade. CCA 202316008. In the hypothetical scenario discussed in the CCA, a hypothetical blockchain, very similar to Ethereum, underwent a change in the method in which it approved and processed…
Read More

Charitable Remainder Annuity Trusts – An Excellent Tool, but Not a Gain Eraser

Cases, Charitable Giving, Estate Planning, Fiduciaries, Income Tax, Tax, Tax Controversy, Tax Court

Charitable remainder annuity trusts, or CRATS, are excellent estate planning vehicles and provide a litany of benefits to those who implement them, but as Devin Mills discussed in his recent article on the 2023 IRS Dirty Dozen list, the IRS considers CRATS as one of the legitimate tax strategies that are often abused by taxpayers.[1]…
Read More

Directions