Author: Savannah Rollins
Water damage in a home is no joke. Not only does it lead to costly repairs, but you could start growing mold. Left untreated for a long time, water leaks could mean it’s really hard to find a willing buyer for your property when you’re ready to move. It’s always in your best interest to detect water leaks sooner than later. Of course you’ll look for obvious signs like a puddle on your bathroom floor or a dripping ceiling. But there are other ways to spot a water leak that are not as obvious. You could have an internal or…
The Case A recent case from California’s Office of Tax Appeals brings some clarity to how strictly California dates a change of residency for income tax purposes when a nonresident claims to have moved to California shortly after a liquidity event. The case, Appeal of Housman, OTA Case No. 18010200 (November 2022), in some ways is the flipside of Appeal of J. Bracamonte, a case involving a resident who claimed to move to another state shortly after a stock sale. Bracamonte is discussed in detail in this article. Both cases went badly for the taxpayers, and for many of the…
This is a wonderful milestone – 40 years of the collaboration of the Silicon Valley TEI Chapter, the IRS and the SJSU MST Program to reach our 40th Annual TEI-SJSU High Tech Tax Institute. We’ll be back at the Crown Plaza Cabana in Palo Alto on November 4 & 5, 2024.We have an outstanding group of experts in many hot tech areas including equity comp, M&A, IP location, Pillar 2, international developments, how generative AI is being used in the corporate tax department, federal controversy, ASC 740, the latest in R&D tax rules, and more.AND … IRS Commissioner Danny Werfel…
The Issue After years of wrangling with the issue, California has just enacted legislation to eliminate a state income tax savings strategy some California residents have pursued by establishing a non-grantor gift trust (ING). These trusts are often called WINGs, DINGs, and NINGS, a reference to the three states that first marketed them: Wyoming, Delaware, and Nevada. INGs can offer significant federal estate planning advantages. But they also allow residents of states with high income-tax rates, like California, to avoid paying state taxes on undistributed non-California-source income. The income can then grow free of state income taxes in the trust…
Every week, there are several news releases from the Tax Division of the Department of Justice and the IRS Criminal Investigation (CI) unit about people caught in tax evasion and sometimes not only stealing from all of their fellow taxpayers but also employer or others. I encourage you to scan recent headlines for the reports of catching some of these bad actors.But, of course, many are not caught and some are caught after the statute of limitations has closed for some years of taking deductions they were not entitled to. If civil fraud is involved, the statute of limitations remains…
What’s Happening A recent poll of adult California residents shows the vast majority are satisfied with the state, but about 40% are considering leaving. Only 18% of those say they are considering a move “very seriously.” The major reason given for a possible move is economic: over 60% say living expenses are motivating their planning. The poll doesn’t mention taxes. Presumably, however, the 18% of those who are very seriously considering changing residency because they disagree with “California’s policies and laws” may have taxes in mind. The poll can be found here. The poll caused quite a media stir. That’s…
In May 2024 I had the opportunity to participate in the California Lawyers Association Tax Section’s DC Delegation. Participants identify a tax rule in need of reform and draft a paper explaining why change is needed and offer proposals for that reform.My May paper was on modifying and clarifying the American Opportunity Tax Credit (AOTC) which offers up to $10,000 of tax credit (subsidy) to most families for a child (or themselves) in the first four years of college ($2,500 maximum credit for year for up to four years).The phaseout income levels for the credit are quite high so at…
If you’re thinking about selling your home in the San Francisco Bay Area, one of the most important questions on your mind is likely, “How long will it take to sell?” It’s a valid concern, as timing can impact everything from your moving plans to your financial decisions. While every real estate market is unique, it’s helpful to consider both national trends and local data to get a clearer picture of what you might expect. Nationally, homes have been staying on the market a bit longer than in recent years, but what about here in the Bay Area? Each county…
Real estate was significantly affected by the global pandemic. Not only did some sellers hunker down and take their home off the market, but other potential buyers were out of work and had to pull their offers. Considering that emotions were already high, the additional steps required to process a transaction became extremely overwhelming. While the market has turned around, there are still some communities with high coronavirus numbers and protocols in place. We will explore why more people chose to sell their home directly in Sacramento during the height of Covid-19, and why they may continue to do so.…
With the 2024 Presidential election fast approaching, you might be wondering what impact, if any, it’s having on the housing market. Let’s break it down. Election Years Bring a Temporary Slowdown In any given year, home sales slow down slightly in the fall. It’s a typical, seasonal trend. However, according to data from BTIG, in election years there’s usually a slightly larger dip in home sales in the month leading up to Election Day (see graph below): Why? Uncertainty. Many consumers hold off on making major decisions or purchases while they wait to see how the election will play out.…