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The 2024 archive

Everything Fortress published in 2024, newest first — the developments and planning windows that defined the year.

19 pieces in this view

AnalysisDecember 20244 min read

What's Coming in 2025: The Estate Exemption Hits $13.99 Million as the Sunset Stays on the Calendar

The IRS has released the 2025 inflation adjustments, and the federal estate and gift exemption climbs to $13.99 million per person, with the annual gift exclusion rising to $19,000. For families doing year-end and early-2025 gifting, those are the figures to use. But the larger fact has not changed: under current law, the elevated exemption is still scheduled to fall after 2025. The higher 2025 numbers widen the window — they do not extend it.

ReadTrusts & Estates

AnalysisDecember 20244 min read

Nationwide Whiplash: The CTA Injunction Saga Closes 2024 in Limbo

In the span of a few weeks, beneficial ownership reporting under the Corporate Transparency Act was frozen nationwide by a Texas court, reinstated by the Fifth Circuit, and frozen again by a different Fifth Circuit panel — all as the January 1 deadline for millions of companies bore down. As the year ends, the requirement is suspended, but precariously, and the litigation is unresolved. The only defensible posture is to be ready to file the moment the courts say so.

ReadControversy & Compliance

AnalysisNovember 20245 min read

Inherited IRAs, Settled: Final Regulations Confirm Annual RMDs Inside the 10-Year Rule

After four years of ambiguity and four years of penalty waivers, Treasury has finalized the rules for inherited retirement accounts. The answer is the one many advisors feared and the IRS had signaled: many beneficiaries subject to the ten-year rule must also take annual required minimum distributions in the intervening years. The waivers end with 2024. Beginning in 2025, the affected beneficiaries have to take those annual distributions — and the ones who waited will feel the compression.

ReadBusiness & Planning

AnalysisNovember 20241 min read

Trust Distribution Planning Before Year-End: Why Timing and DNI Still Matter

Year-end trust planning is often framed as a paperwork exercise, but the more important issue is whether fiduciaries understand how distributions, distributable net income, and beneficiary-level outcomes interact before the year closes.

ReadTrusts & Estates

AnalysisOctober 20245 min read

Six Hundred Pages of CAMT: What the Proposed Corporate Minimum Tax Regs Mean Beyond Billion-Dollar Companies

Treasury has released the long-awaited proposed regulations for the corporate alternative minimum tax — roughly six hundred pages of them. The headline is familiar: a 15 percent minimum tax on the financial-statement income of corporations averaging over a billion dollars. The detail is where the surprise lives. The aggregation and partnership rules in the proposed regulations can pull entities and structures into the regime that do not look, at a glance, like billion-dollar companies. For large structures, the threshold is not the whole story.

ReadBusiness & Planning

AnalysisSeptember 20244 min read

The IRS Targets Partnership Basis Shifting: New Disclosure Rules and Economic-Substance Risk

The IRS has opened a coordinated campaign against a category of related-party partnership transactions it views as basis shifting without substance. The June 2024 guidance package does two things at once: it proposes to make these transactions reportable, and it signals that the economic-substance doctrine — and its strict-liability penalty — is in play. Partnerships and related-party structures that have used these techniques, or are contemplating them, need to review their exposure now.

ReadControversy & Compliance

AnalysisSeptember 20241 min read

SALT Workarounds for Pass-Through Owners: Why Entity-Level Elections Still Deserve Review

By 2024, pass-through entity tax elections were no longer novel. That is exactly why they risk being overlooked. An election that was reviewed once and then ignored can quietly become suboptimal as income, ownership, and state footprint change.

ReadState & Local

AnalysisAugust 20244 min read

The 1099-DA Era Is Real: Final Crypto Broker Reporting Rules for Custodial Platforms

Treasury has finalized the rules requiring custodial digital-asset brokers to report customer transactions on a new Form 1099-DA. The reporting starts with sales in 2025, which means the compliance build has to happen now. Centralized exchanges and other custodial platforms are squarely covered. Non-custodial and decentralized actors got more time — but they should read this as a deferral, not an exemption.

ReadControversy & Compliance

AnalysisAugust 20244 min read

Section 174 Relief Is Dead in the Senate: How to Run the Rest of 2024 Without the Fix

The bill that would have restored immediate expensing of domestic research costs has failed in the Senate. After House passage in January, a cloture vote fell short on August 1, and the retroactive fix is off the table for this filing season. For research-intensive companies that had been hoping, the planning question is no longer whether to wait — it is how to run the rest of the year cleanly under current law.

ReadBusiness & Planning

AnalysisJuly 20244 min read

Chevron Is Gone: What Loper Bright Means for Challenging Treasury Regulations

The Supreme Court has overruled *Chevron*, the forty-year-old doctrine that told courts to defer to an agency's reasonable reading of an ambiguous statute. Courts must now interpret statutes themselves. For tax, this is not an abstract administrative-law event. It changes the odds in every dispute that turns on whether a Treasury regulation is a fair reading of the Internal Revenue Code — and it should change how taxpayers and the IRS alike approach contested positions.

ReadControversy & Compliance

AnalysisJuly 20244 min read

Prevailing Wage and Apprenticeship, Finalized: The Documentation Burden Behind the 5x Clean-Energy Credit

Treasury has finalized the rules that govern the single largest variable in clean-energy tax credits: the five-times multiplier. The headline number is unchanged — meeting the prevailing-wage and apprenticeship requirements can take a base credit and multiply it fivefold. What the final regulations make clear is that the multiplier is now a documentation discipline as much as a labor practice. Projects that cannot prove compliance will not capture it.

ReadBusiness & Planning

AnalysisJuly 20241 min read

Real Estate Cost Segregation Timing: Why the Best Study Is Not Always the Latest One

Cost segregation remains powerful, but the timing question is often more important than the study itself. Owners need to understand whether the property, holding horizon, and depreciation environment still support the desired result.

ReadTrusts & Estates

AnalysisJune 20244 min read

Buy-Sell Agreements After Connelly: Why Corporate-Owned Life Insurance Just Got More Expensive at Death

A unanimous Supreme Court has held that life insurance a corporation receives to redeem a deceased owner's shares increases the company's value for estate-tax purposes — and that the obligation to redeem those shares does not offset it. For closely held businesses that fund their buy-sell agreements through entity-owned policies, this is not a marginal technicality. It can convert a succession plan into an estate-tax problem. The structures need a hard look now, not after the next death.

ReadTrusts & Estates

AnalysisJune 20244 min read

Realization Survives, but the Door Stays Open: Reading Moore v. United States

The Supreme Court has upheld the 2017 transition tax on accumulated foreign earnings. It did so on narrow grounds — and it pointedly declined to decide whether the Constitution requires income to be "realized" before it can be taxed. For owners with interests in foreign corporations, the immediate question is settled. For the larger fight over wealth taxes and mark-to-market regimes, the decision settles very little. The constitutional question that everyone was watching is still open.

ReadBusiness & Planning

AnalysisMay 20241 min read

Entity Cleanup Before Growth: Why Expansion Plans Expose Old Structuring Problems

Growth tends to surface problems that a stable business can ignore: outdated ownership records, mismatched entity elections, unclear intercompany arrangements, and filing footprints that no longer align with operations.

ReadBusiness & Planning

AnalysisApril 20244 min read

The Section 174 Fix That Wasn't: Why House Passage Is Not Permission to Stop Capitalizing

The House passed a bill that would restore immediate expensing of domestic research costs. That is real, and it is encouraging for companies that have been absorbing larger tax bills under mandatory capitalization. But it is not law. Until the Senate acts and the President signs, IRC § 174 still requires five-year amortization of domestic research and experimental expenditures — and returns filed this season must reflect the law as it actually is.

ReadBusiness & Planning

AnalysisMarch 20244 min read

The CTA's First Crack: Why a Favorable Ruling Does Not Suspend Your Filing Obligation

A federal court has held the Corporate Transparency Act unconstitutional. That is a real development, and it matters. But for the overwhelming majority of reporting companies, it changes nothing operational: the obligation to file beneficial ownership information with FinCEN remains in force. The mistake to avoid this quarter is reading a single district-court win as permission to stop.

ReadControversy & Compliance

AnalysisMarch 20241 min read

Q1 Estimated Tax Planning for Owners: Avoiding Early-Year Underpayment Drift

For owner-led businesses and pass-through structures, first-quarter tax planning matters more than many teams admit. Small forecasting misses in Q1 can become expensive underpayment patterns by year-end.

ReadBusiness & Planning

Tax AlertJanuary 20241 min read

BOI Reporting Goes Live: Deadlines, Exemptions, and Immediate Action Items

Beneficial ownership information reporting is now live. For many businesses, the most immediate risk is not complexity in the rule itself, but the mistaken assumption that the rule does not apply to them.

ReadControversy & Compliance

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A development from this year still in play?

Several positions opened in earlier years remain live. If one maps to a decision you are weighing, the conversation worth having is a focused one.

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