Cummings & Lockwood

Alerts & Updates

The IRS Clarifies that Private Equity, Hedge Funds and Other Partnerships are Subject to Withholding Requirements When Foreign Persons are Involved

May 22, 2019

On May 7, 2019, the IRS issued proposed regulations for new code section 1446(f), which requires withholding of income tax when a foreign person recognizes gain or loss from the sale or exchange of certain partnership interests, as described in IRC 864(c)(8).

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New IRS Guidance on Opportunity Zone Investments

April 16, 2019

On April 17, 2019, the IRS and U.S. Treasury Department issued proposed regulations (Proposed Treas. Reg. Sec. 1400Z-2), that provide new guidance for qualified "Opportunity Funds" investing in "Opportunity Zones."

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Increase in New York Real Property Transfer Taxes, Including “Progressive Mansion Tax”

April 10, 2019

As part of the 2019/2020 New York State Budget Bill that was passed, New York included a progressive mansion tax with a top tax rate of 3.90% on properties purchased for $25 million or above.

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NY Extends the Three Year Look Back for Lifetime Gifts when Calculating the New York Estate Tax

April 3, 2019

The New York estate tax exemption currently is $5,740,000.  The exemption is adjusted for inflation and will increase over time.

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Client Alert - Connecticut's Changes to Estate and Gift Tax Exemptions - Confirmed!

March 11, 2019

In 2019, the Connecticut exemption amount from estate and gift tax has been increased from its prior level of $2,600,000 per individual to $3,600,000.  As we have reported, there has been some confusion as to what is to occur in 2020 and future years because in May of 2018, Governor Dannel P. Malloy and the Connecticut legislature enacted two different bills with respect to the Connecticut estate and gift tax.

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Governor Lamont’s Budget Proposal Includes Potential Changes to Connecticut’s Estate and Gift Tax

February 19, 2019

Governor Lamont’s proposed budget titled “A Path Forward” for Fiscal Year 2020 and 2021 was announced on February 20, 2019 (the “Proposed Budget”) and includes changes to Connecticut’s estate and gift tax regime.

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Beware of Scam Targeting Owners of LLCs

January 3, 2019

Connecticut clients should be aware of a large scale scam targeting owners of Limited Liability Companies. 

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2018 Cummings & Lockwood Annual Update

December 30, 2018

As we complete our 110th year, our Partners are grateful to have assisted existing and new clients, serving a range of individuals, families, charitable entities and businesses.

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December 2018 Client Update

December 2018

Cummings & Lockwood’s Private Clients Group advises on changes in the federal and state tax laws and general estate planning developments in 2018, including estate, gift and GST tax rates and exemptions

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Financial Crimes Enforcement Network Revises Geographic Targeting Orders; Lowering Dollar Threshold and Including Additional Geographic Locations

On November 15, 2018, the Financial Crimes Enforcement Network of the U.S. Treasury Department (“FinCEN”) announced that it had revised its existing “Geographic Targeting Orders” (“GTOs”) to expand the included geographic areas, significantly lower the applicable dollar threshold, make said threshold consistent across all geographic areas, and include purchases made using virtual currency. 

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Investments in Opportunity Zones Allow Investors to Defer and Possibly Eliminate Capital Gains as Potential Alternative to 1031 Exchanges

On October 19, 2018, the U.S. Treasury Department released proposed regulations relating to the Opportunity Zones program, which is an investment tool established by the 2017 Tax Cuts and Jobs Act allowing investors in certain “Opportunity Zones” to defer and partially eliminate capital gains taxes on gains realized from selling real or personal property. 

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Regulations Proposed by IRS Would Eliminate Lingering Concerns About Clawback

November 19, 2018

On November 20, 2018, the Internal Revenue Service issued proposed regulations to address one of the lingering concerns of using the increased gift tax exemption on gifts prior to 2026 - the so-called “clawback.”

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