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Season's GreetingsFor so many of us, 2023 has been a difficult year.  The so-called end of the COVID-19 pandemic looked to be a bright spot in our lives, but with wars raging in Ukraine and Gaza and dramatic social unrest at our doors, we continue to face difficult times.

I am extremely grateful for the unwavering support of family, friends, clients, and my law colleagues, especially in these troubling times!

During these trying times, we have had to be mindful of the good that surrounds us.  As the Ancient Greek philosopher Aristotle is accredited with saying:

“It is during our darkest moments that we must focus to see the light.”

During 2023, I was able to speak in person at several tax conferences.  It was wonderful to actually see and visit with conference attendees rather than delivering a lecture into a computer screen’s virtual abyss.  This year, I was fortunate to have the opportunity to speak at the following tax conferences:

New York & CaliforniaThe 82nd Institute on Federal Taxation (IFT) will be held in New York City on October 22-27, 2023, and in Berkeley, California, on November 12-17, 2023.

This year, I will be presenting my latest white paper, “A Journey Through Subchapter S / A Review of the Not So Obvious & The Many Traps That Exist for the Unwary.”  Our discussion will examine the potpourri of issues arising from Subchapter S that may not be readily apparent to the tax practitioner, such as matters arising from the single class of stock requirement, the built-in-gains tax, the interplay between Subchapter C and Subchapter S, lingering E&P, and late (or never made) elections.  The session will also alert tax practitioners to traps that exist for the unwary and, in some cases, possible ways to avoid or remedy falling into one of these traps.

University of Notre DameI am pleased to announce that I will be presenting at the 49th Annual Notre Dame Tax & Estate Planning Institute in South Bend, Indiana.  The Institute this year will occur on September 20-22. 

I will be presenting my white paper "Entity Classification – The Check-The-Box Regulations Revisited."  My discussion will cover recent developments in the law relating to entity classification, limitations under the check-the-box regulations, flexibility and planning opportunities created by the regulations, traps that exist for the unwary, and practical planning strategies for tax advisers.

I am extremely grateful to have the opportunity to speak at the Notre Dame Tax & Estate Planning Institute and present among a tremendous panel of speakers, including Jerry Hesch, Paul Lee, Jonathan Blattmachr and Stephen Breitstone.  It looks to be a terrific program for income tax and estate tax attorneys.

View the complete agenda and register using the link to attend the institute in person or to obtain the audio recording and the materials.

2022, like the prior two years, has been difficult.  The COVID-19 pandemic and social unrest continues to be at the forefront of our existence.  On top of that, inflation and possible recessionary times are among us.

Thanks to the unwavering support of family, friends, clients, and colleagues, we are enduring through these turbulent times.  I am so grateful for these relationships!

I have had to constantly be mindful of the good things going on around us.  As American Poet Walt Whitman is accredited with saying:

NYC and San DiegoThe NYU 81st Institute on Federal Taxation (IFT) returns to in-person programming this year in New York City on October 23-28, 2022, and in San Diego on November 13-18, 2022. 

This year, I will be presenting my white paper “Entity Classification – The Check-The-Box Regulations Revisited."  Our discussion will cover recent developments in the law relating to entity classification, limitations under the check-the-box regulations, flexibility and planning opportunities created by the regulations, traps that exist for the unwary, and practical planning opportunities for tax advisers.

I am extremely grateful to have had the opportunity to present with IFT for more than a decade. During this year’s Institute, I will again be presenting as part of the Closely-Held Business program, chaired by my esteemed colleague Jerry David August, on the mornings of October 27 (NYC) and November 17 (San Diego)

Happy Holidays

Like last year, 2021 has been a difficult year.  The COVID-19 pandemic continues to be at the forefront of everyone’s existence.  On top of that, the Delta variant and the most recently discovered Omicron variant have entered the picture.

Personal loss, social unrest, lofty economic hurdles and limitations on personal interaction have permeated the planet for almost 24 months.  For at least the foreseeable future, it appears these strained conditions will continue.    

Thanks to the steadfast support of family, friends, clients and business colleagues, we are persevering throughout these trying times.  I am so grateful for these relationships!

The Oregon Society of Certified Public Accountants (OSCPA) will be hosting its 2021 Annual Real Estate Conference as a live webcast on Wednesday, June 9, 2021. I’ve been a frequent speaker at the OSCPA’s conferences over the past 30+ years. This year, I am looking forward to present on “Section 1031 Exchanges: A Look At Recent Developments and Other Tax Deferral Alternatives.”

For the second year in a row, the due date for the filing of income tax returns and the payment of taxes was extended. For most taxpayers, the extended deadline brought glee. For the tax return preparation community, however, while the extended time period was undoubtedly necessary, it offered little relief. Instead, it served to prolong the busiest and most stressful time of year.

Season's Greetings2020 has been a rough year for all of us.  We have experienced personal loss, social unrest, economic challenges and significant limitations on personal interaction.  While the impacts of these conditions may manifest themselves differently in each of us, we have all been faced with some of the loftiest challenges we had ever likely encountered.  It is my sincere hope that with the COVID-19 vaccines recently approved by the Federal Drug Administration, we will return to some sort of normalcy in 2021.

It is a good time for us all to focus on the blessings in our lives.  One of the many blessings in my life was the opportunity of education.  It was not exactly given to me.  I had to work to pay for my education – many times working multiple jobs simultaneously – but the fact that a fine, quality education was available to me is a huge blessing.  Along the way, during college, law school and post-law school studies in taxation, I had the fortune of having terrific mentors.  One of my mentors, Professor David Richardson (now a retired professor and Chair of the Graduate Tax Program at the University of Florida College of Law), advised me that once I entered the practice of law, I had a duty to the profession to share the wealth of knowledge that I had been so fortunate enough to attain from my studies and that I would attain in my law practice.  That statement from Professor Richardson resonated strongly with me and has continuously been at the forefront of my career goals.

CupcakeIt was one year ago today that two esteemed law firms based out of the Pacific Northwest merged to form Foster Garvey PC.  After going at it alone for a combined era that spanned more than 170 years, Garvey Schubert Barer, PC and Foster Pepper PLLC joined forces.  As a result, a full-service law firm of more than 150 attorneys with offices in Seattle, Portland, Washington, D.C., New York, Spokane and Beijing, China, emerged.

Shortly after the merger, the COVID-19 pandemic hit all people across the globe.  Then, social unrest throughout the United States joined the center stage, with continuing protests and riots occurring in almost every major city.  Most recently, wildfires of historic magnitude hit the Pacific Northwest.  On top of all of these life challenges, the attorneys and staff of Foster Garvey PC worked hard to maintain a focus on serving clients and our communities, as well as integrating the people and systems of two organizations.

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Larry J. Brant
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Larry J. Brant is a Shareholder and the Chair of the Tax & Benefits practice group at Foster Garvey, a law firm based out of the Pacific Northwest, with offices in Seattle, Washington; Portland, Oregon; Washington, D.C.; New York, New York, Spokane, Washington; Tulsa, Oklahoma; and Beijing, China. Mr. Brant is licensed to practice in Oregon and Washington. His practice focuses on tax, tax controversy and transactions. Mr. Brant is a past Chair of the Oregon State Bar Taxation Section. He was the long-term Chair of the Oregon Tax Institute, and is currently a member of the Board of Directors of the Portland Tax Forum. Mr. Brant has served as an adjunct professor, teaching corporate taxation, at Northwestern School of Law, Lewis and Clark College. He is an Expert Contributor to Thomson Reuters Checkpoint Catalyst. Mr. Brant is a Fellow in the American College of Tax Counsel. He publishes articles on numerous income tax issues, including Taxation of S Corporations, Reasonable Compensation, Circular 230, Worker Classification, IRC § 1031 Exchanges, Choice of Entity, Entity Tax Classification, and State and Local Taxation. Mr. Brant is a frequent lecturer at local, regional and national tax and business conferences for CPAs and attorneys. He was the 2015 Recipient of the Oregon State Bar Tax Section Award of Merit.

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