News & Insights
Fifth Circuit Rejects "Passive Investor" Test For Limited Partner Self-Employment Tax Exclusion
February 19, 2026As a rule, an individual partner’s distributive share of ordinary business income is included in net earnings from self-employment under Internal Revenue Code § 1402(a) and is subject to federal self-employment tax.
Cummings & Lockwood Attorneys Participate in Columbia Law School Panel on Careers in Private Wealth and Estate Planning
February 17, 2026Laura W. Beck and Wyatt R. Jansen of Cummings & Lockwood will be participating in a panel discussion entitled “Careers in Private Wealth and Estate Planning” hosted by Columbia Law School on February 18. 2025.
IRS Applies Economic Substance Doctrine to Disallow Charitable LLC Tax Benefits
February 11, 2026In the recently released Field Service Advice 20260401F, the Internal Revenue Service concluded that the transfer of a non-voting interest in an investment limited liability company to a tax-exempt public charity should be disregarded for federal income tax purposes because it lacked economic substance.
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US Postal Service Disrupts "Mailbox" Rule for Tax Filing and Payment Deadlines
January 6, 2026Under IRC § 7502, a tax return, refund claim or tax payment is deemed to be filed or paid on the date of the postmark stamped on the envelope in which it was mailed even if received by the IRS days or weeks later.
New York Tax Court Approves "Drop and Swap" Technique in Real Estate Like-Kind Exchange
December 16, 2025An IRC § 1031 like-kind exchange (“LKE”) is a tax-deferred transaction in which the taxpayer sells real estate held for productive use in a trade or business or for investment (“qualifying property”) and reinvests the sales proceeds in other qualifying property.
Connecticut Appellate Court Issues Guidance on Asset-Protection Trusts in Divorce
December 9, 2025A recent Connecticut Appellate Court case provides guidance on an important issue in many high-net-worth divorce cases: whether property in asset-protection trusts is “marital property” subject to equitable distribution.
New York Emphasizes "Substance over Form" In Determining Domicile For Income Tax Purposes
December 8, 2025The determination of domicile can be critical for state tax planning because states which have state level income and/or estate taxes generally impose those taxes on a person domiciled in the state more than on a non-resident.
2025-2026 Estate and Gift Tax Law Update
December 3, 2025In this video, Katherine C. Gent, a Principal in Cummings & Lockwood’s Private Clients Group and based in the firm’s Stamford, Connecticut office, reviews the current federal, Connecticut and New York estate, gift and generation-skipping transfer tax laws.
One Big Beautiful Bill Act: What You Need to Know for Estate, Gift and Income Tax Planning
December 3, 2025In this video, Eva V. Kliegman, a Principal in Cummings & Lockwood’s Private Clients Group and based in the firm’s Greenwich, Connecticut office, covers the aspects of the new tax legislation that affect estate, gift and income tax planning.
Private Foundations: Avoiding Self-Dealing Pitfalls
December 3, 2025In this video, Brianna L. Marquis, a Principal in Cummings & Lockwood’s Private Clients Group and based in the firm’s West Hartford, Connecticut office, covers the tips for successfully administering charitable foundations and provides an in-depth look at the pitfalls of self-dealing
The Benefits and Limitations of 1031 Exchanges for High Net Worth Investors
December 3, 2025In this video, Scott T. Witthuhn, a Principal in Cummings & Lockwood’s Commercial Real Estate and Corporate and Finance Groups and based in the firm’s Stamford, Connecticut office, discusses an overview of the nature, potential benefits and process of 1031 exchanges, particularly for wealth planning purposes.
2025 Private Clients Annual Update
November 18, 2025We hope that you and your family are enjoying a peaceful and healthy 2025. This past year has brought a lot of changes and political and economic debate in Washington and nationally, but for once we find ourselves ending the year with a new level of predictability in the federal gift, estate and generation-skipping transfer (“GST”) tax regime.