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Writings by Frank L. Brunetti

Frank Brunetti has been practicing law for over thirty years in the areas of estate and wealth preservation, tax planning for business entities and complex tax matters. He is admitted to the New Jersey and New York Bars as well as the United States Tax Court.
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Scarinci Hollenbeck remains committed not only to providing top-tier legal services but also to regularly providing information and resources to our client base and internet following. Client Alerts provided by our attorneys supply businesses, municipalities, and more with the latest and relevant legal updates that may impact them and how they might be able to proceed.
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Can the filing of an amended tax return result in the waiver of the attorney-client privilege between taxpayer and accountant? post image

Can the filing of an amended tax return result in the waiver of the attorney-client privilege between taxpayer and accountant?

U.S. v. Adams, 122 AFTR 2d ¶2018-5380, (DC MN 10/27/2018) Under United States v. Kovel, 296 F.2d 918, 921–22, 9 AFTR 2d 366 (2nd Cir. 1961) the attorney-client privilege applies to an individual’s communications with an accountant if the communications are “made in confidence for the purpose of obtaining legal advice from the lawyer”.  The party […]

Author: Frank L. Brunetti

Link to post with title - "Can the filing of an amended tax return result in the waiver of the attorney-client privilege between taxpayer and accountant?"
Why setting up an LLC to run a Cannabis Business May Not Be Tax Wise post image

Why setting up an LLC to run a Cannabis Business May Not Be Tax Wise

When forming any type of New Jersey business, choosing the proper legal structure is one of the most important decisions you will make. The choice is even more challenging for New Jersey cannabis businesses, which still face a number of legal uncertainties under both federal and state law. 

Author: Frank L. Brunetti

Link to post with title - "Why setting up an LLC to run a Cannabis Business May Not Be Tax Wise"
Property Tax Deductions for 2017 Might Not Include 2018 Prepayments post image

Property Tax Deductions for 2017 Might Not Include 2018 Prepayments

In Information Letter 2018-0009, the IRS has implied that actions taken in Dec. 2017 by the New Jersey Department of Community Affairs, which ordered NJ municipalities to accept payments for 2018 property taxes in the calendar year 2017, will not result in those payments generating 2017 federal income tax deductions.

Author: Frank L. Brunetti

Link to post with title - "Property Tax Deductions for 2017 Might Not Include 2018 Prepayments"
The Tax Cuts and Jobs Act Makes Modifications Created by the ABLE Act post image

The Tax Cuts and Jobs Act Makes Modifications Created by the ABLE Act

The Tax Cuts and Jobs Act Makes Modifications to ABLE Accounts Created by the Achieving a Better Life Experience Act of 2014 I have been involved with planning for the disabled for many years. In 1984, I prepared a trust for a disabled child so that the child could qualify for SSDI. The article, “Special […]

Author: Frank L. Brunetti

Link to post with title - "The Tax Cuts and Jobs Act Makes Modifications Created by the ABLE Act"
Will IRS Modify Schedule UTP for Uncertain Tax Positions or Not? post image

Will IRS Modify Schedule UTP for Uncertain Tax Positions or Not?

Additional tax changes may be on the horizon for U.S. businesses. However, at this point, it is too soon to tell whether they will ease or expand compliance burdens. The Internal Revenue Service (IRS) is currently evaluating whether to eliminate or modify Schedule UTP, the Uncertain Tax Position Statement, following a report by the Treasury Inspector General for Tax Administration that raised concerns about its effectiveness.

Author: Frank L. Brunetti

Link to post with title - "Will IRS Modify Schedule UTP for Uncertain Tax Positions or Not?"
IRS to Ramp Up Criminal Prosecution to Combat Offshore Tax Avoidance post image

IRS to Ramp Up Criminal Prosecution to Combat Offshore Tax Avoidance

The Internal Revenue Service (IRS) announced that the Offshore Voluntary Disclosure Program (OVDP) will be closing on September 28, 2018. However, that does not mean that the IRS is no longer making offshore tax avoidance a top enforcement priority. According to the IRS, the OVDP has simply outlived its usefulness. It appears that the program, […]

Author: Frank L. Brunetti

Link to post with title - "IRS to Ramp Up Criminal Prosecution to Combat Offshore Tax Avoidance"
IRS Notice of Deficiency Ruled Untimely in Win for Scarinci Hollenbeck Client post image

IRS Notice of Deficiency Ruled Untimely in Win for Scarinci Hollenbeck Client

IRS Notice of Deficiency Ruled Untimely in Win for Scarinci Hollenbeck Client In Mehrdad Rafizadeh v. Commissioner, the U.S. Tax Court granted summary judgment for the taxpayer, holding the Internal Revenue Service’s (IRS) deficiency notice was untimely. The court specifically held that the IRS could not rely on the six-year statute of limitations set forth in Internal […]

Author: Frank L. Brunetti

Link to post with title - "IRS Notice of Deficiency Ruled Untimely in Win for Scarinci Hollenbeck Client"
In-Depth Look At Tax Accounting Changes Under the Tax Cuts And Jobs Act (2017) post image

In-Depth Look At Tax Accounting Changes Under the Tax Cuts And Jobs Act (2017)

Congress Recently Passed the Tax Cuts and Jobs Act (2017), Which Will Usher in an Overhaul of Tax Accounting Changes Recently, my book “Federal Tax Accounting” was published by Commerce Clearing House (CCH) covering a wide range of tax accounting topics such as tax accounting doctrines, entities tax years, adoption and methods of accounting, the […]

Author: Frank L. Brunetti

Link to post with title - "In-Depth Look At Tax Accounting Changes Under the Tax Cuts And Jobs Act (2017)"
New Partnership Tax Audit Rules Effective 2018 post image

New Partnership Tax Audit Rules Effective 2018

We Are Hosting An Event Regarding The New Partnership Tax Audit Rules We are hosting a seminar discussing the new tax audit rules effective January 1, 2018. The seminar will be hosted in our Lyndhurst, NJ office on October 24, 2017. The new procedure is the Centralized Partnership Audit Regime (CPAR). The CPAR default rule applies […]

Author: Frank L. Brunetti

Link to post with title - "New Partnership Tax Audit Rules Effective 2018"
IRS Streamlines Application Process for Small Exempt Organization Status post image

IRS Streamlines Application Process for Small Exempt Organization Status

The IRS recently finalized regulations that will streamline the process for obtaining small exempt organization status The Internal Revenue Service (IRS) recently finalized regulations that will streamline the process for obtaining small exempt organization status. Form EZ-1023 is welcome news given the time and information required to complete the standard Form 1023. Benefits of Small […]

Author: Frank L. Brunetti

Link to post with title - "IRS Streamlines Application Process for Small Exempt Organization Status"
Rentals Not Treated as Passive Investment Income for S Corporation Purposes post image

Rentals Not Treated as Passive Investment Income for S Corporation Purposes

In PLR 201725022, a corporation received rental income from its leasing of offices for medical and related services.  The taxpayer intended the rental income from its maintenance-related operations as non-passive investment income under section 1362(d)(3)(c)(i). In PLR 201725022, a corporation received rental income from its leasing of offices for medical and related services.  The taxpayer intended the rental […]

Author: Frank L. Brunetti

Link to post with title - "Rentals Not Treated as Passive Investment Income for S Corporation Purposes"
IC-Disc...Is it Right for Your Business? post image

IC-Disc...Is it Right for Your Business?

Now that President Trump has made it a priority to bring back manufacturing to the United States, now might be the time to consider an IC-Disc (Interest Charge Domestic International Sale Corporation). An IC-Disc reflects a special tax preference enacted by Congress to strengthen export sales. If a domestic corporation qualifies and elects to be […]

Author: Frank L. Brunetti

Link to post with title - "IC-Disc...Is it Right for Your Business?"

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