Real estate investors rarely get a second chance to revisit a tax election once it has been made, especially one the Internal Revenue Code labels “irrevocable.” Revenue Procedure 2026‑17 changes that. In a significant development for the industry, the IRS is now...
Purpose and Scope Charitable giving has become an important goal of many entrepreneurs who have accumulated substantial wealth in closely held businesses. Among the many philanthropic vehicles available, the private foundation stands apart for its capacity to support...
Overview The freeze partnership technique (the "technique") has been used for decades to transfer wealth to the next generation while reducing estate, gift, generation-skipping and income taxes. Despite being explicitly authorized under Internal Revenue Code...
Recent legislative developments, including the One Big Beautiful Bill Act (OBBBA) and the resulting expansion of the federal lifetime gift and estate tax exemption, have created a significant planning window for high‑net‑worth individuals to deploy exemption, either...
I. Introduction The Internal Revenue Code (the “Code”) and accompanying regulations provide no explicit guidance directly addressing disguised sales of partnership interests. While the IRS issued proposed regulations under Treas. Reg. § 1.707-7 in 2004...
Ohio lawmakers completed a significant override of Governor Mike DeWine's budget vetoes in October 2025, fundamentally altering how local governments and school districts can structure future property tax levies. This action by the General Assembly, combined with...
This article is Part One of a multi-part analysis by KJK that will continue to summarize the OBBBA’s implications on various taxpayers and industries. Signed into law on July 4, 2025, the One Big Beautiful Bill Act (“OBBBA”) delivers sweeping federal policy changes...
In a landmark decision, the U.S. Supreme Court’s decision in Connelly v. United States will require closely-held business owners to reconsider their current buy-sell arrangement in order to avoid additional federal estate tax. Now under the Court’s holding in...
Artificial Intelligence (AI) has been making waves across various industries, and tax law is no exception. Using AI in tax law can bring significant benefits, including analyzing data quickly, identifying patterns, and identifying recent law changes. However, as...
During the height of the pandemic, the Ohio legislature passed House Bill 197, which temporarily suspended the requirement that an employer withhold to the municipality in which an employee performed services. The law allowed an employer to continue withholding to the...