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  • Section 83(b) Elections: When Can You Make One, When Can’t You Make One, And What Are Common Misconceptions?

    Section 83(b) Elections: When Can You Make One, When Can’t You Make One, And What Are Common Misconceptions?
    2026/08/31

    In episode 60 of How Tax Works, Matt Foreman discusses equity grants, 83(b) elections, and common misconceptions with 83(b) elections.

    How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, breaking down complex concepts for a clearer understanding of how tax laws impact your financial decisions.

    Follow us on Bluesky:
    @howtaxworks.bsky.social

    This podcast may be considered attorney advertising. This podcast is not presented for purposes of legal advice or for providing a legal opinion. Before any of the presenting attorneys can provide legal advice to any person or entity, and before an attorney-client relationship is formed, that attorney must have a signed fee agreement with a client setting forth the firm’s scope of representation and the fees that will be charged.

    This Podcast is Hosted by:
    Falcon Rappaport & Berkman LLP
    1185 Avenue of the Americas, Suite 1415
    New York, NY 10036
    (212) 203 -3255
    info@frblaw.com
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    30 分
  • Substantial Economic Effect and Section 704(b) of the Internal Revenue Code

    Substantial Economic Effect and Section 704(b) of the Internal Revenue Code
    2026/08/18

    In episode 59 of How Tax Works, Matt Foreman discusses allocations and distributions, and the requirement that the allocations have Substantial Economic Effect, which is broken into two parts, (i) that the allocations have economic effect and (ii) that the economic effect is substantial on a pre-tax and post-tax basis.

    How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, breaking down complex concepts for a clearer understanding of how tax laws impact your financial decisions.

    Follow us on Bluesky:
    @howtaxworks.bsky.social

    This podcast may be considered attorney advertising. This podcast is not presented for purposes of legal advice or for providing a legal opinion. Before any of the presenting attorneys can provide legal advice to any person or entity, and before an attorney-client relationship is formed, that attorney must have a signed fee agreement with a client setting forth the firm’s scope of representation and the fees that will be charged.

    This Podcast is Hosted by:
    Falcon Rappaport & Berkman LLP
    1185 Avenue of the Americas, Suite 1415
    New York, NY 10036
    (212) 203 -3255
    info@frblaw.com
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    24 分
  • Penalties for Late Filed Forms 3520, 3520-A, 5471, and 5472

    Penalties for Late Filed Forms 3520, 3520-A, 5471, and 5472
    2026/08/03

    In episode 58 of How Tax Works, Matt Foreman discusses Zhang v. IRS, No. 4:24-cv-08210 (N.D. Cal. 2026), which held that the IRS does not need to file a civil lawsuit to impose penalties for a late-filed Form 3520. Zhang is a related case to Farhy, and applies the same principles to penalties for late- or non-filed Forms 3520-A, 5471, and 5472

    How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, breaking down complex concepts for a clearer understanding of how tax laws impact your financial decisions.

    Follow us on Bluesky:
    @howtaxworks.bsky.social

    This podcast may be considered attorney advertising. This podcast is not presented for purposes of legal advice or for providing a legal opinion. Before any of the presenting attorneys can provide legal advice to any person or entity, and before an attorney-client relationship is formed, that attorney must have a signed fee agreement with a client setting forth the firm’s scope of representation and the fees that will be charged.

    This Podcast is Hosted by:
    Falcon Rappaport & Berkman LLP
    1185 Avenue of the Americas, Suite 1415
    New York, NY 10036
    (212) 203 -3255
    info@frblaw.com
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    20 分
  • New York’s Pied-a-Terre Tax

    New York’s Pied-a-Terre Tax
    2026/07/20

    In episode 57 of How Tax Works, Matt Foreman discusses New York City’s brand new Pied-a-terre tax, outlining some of its most interesting points and potential audit issues

    How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, breaking down complex concepts for a clearer understanding of how tax laws impact your financial decisions.

    Follow us on Bluesky:
    @howtaxworks.bsky.social

    This podcast may be considered attorney advertising. This podcast is not presented for purposes of legal advice or for providing a legal opinion. Before any of the presenting attorneys can provide legal advice to any person or entity, and before an attorney-client relationship is formed, that attorney must have a signed fee agreement with a client setting forth the firm’s scope of representation and the fees that will be charged.

    This Podcast is Hosted by:
    Falcon Rappaport & Berkman LLP
    1185 Avenue of the Americas, Suite 1415
    New York, NY 10036
    (212) 203 -3255
    info@frblaw.com
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    28 分
  • The Curious Case of Kwong (and Adbo), and the Abatement of Interest and Penalties

    The Curious Case of Kwong (and Adbo), and the Abatement of Interest and Penalties
    2026/07/06

    In episode 56 of How Tax Works, Matt Foreman discusses Kwong v. United States, 179 Fed. Cl. 382 (2025), specifically whether interest and penalties must be abated, plus bonus commentary about whether Kwong will be reversed on appeal.

    How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, breaking down complex concepts for a clearer understanding of how tax laws impact your financial decisions.

    Follow us on Bluesky:
    @howtaxworks.bsky.social

    This podcast may be considered attorney advertising. This podcast is not presented for purposes of legal advice or for providing a legal opinion. Before any of the presenting attorneys can provide legal advice to any person or entity, and before an attorney-client relationship is formed, that attorney must have a signed fee agreement with a client setting forth the firm’s scope of representation and the fees that will be charged.

    This Podcast is Hosted by:
    Falcon Rappaport & Berkman LLP
    1185 Avenue of the Americas, Suite 1415
    New York, NY 10036
    (212) 203 -3255
    info@frblaw.com
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    21 分
  • Entity Selection Part II: Payroll Taxes in the Era of Soroban Capital Partners and Sirius Solutions

    Entity Selection Part II: Payroll Taxes in the Era of Soroban Capital Partners and Sirius Solutions
    2026/06/22

    In episode 55 of How Tax Works, Matt Foreman discusses S Corps (again), the viability of the GP/LP structure, the Fifth Circuit’s decision in Sirius Solutions, and the future of section 1402(a)(13) of the Internal Revenue Code.

    How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, breaking down complex concepts for a clearer understanding of how tax laws impact your financial decisions.

    Follow us on Bluesky:
    @howtaxworks.bsky.social

    This podcast may be considered attorney advertising. This podcast is not presented for purposes of legal advice or for providing a legal opinion. Before any of the presenting attorneys can provide legal advice to any person or entity, and before an attorney-client relationship is formed, that attorney must have a signed fee agreement with a client setting forth the firm’s scope of representation and the fees that will be charged.

    This Podcast is Hosted by:
    Falcon Rappaport & Berkman LLP
    1185 Avenue of the Americas, Suite 1415
    New York, NY 10036
    (212) 203 -3255
    info@frblaw.com
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    24 分
  • Substance v. Form Part III: Project Soy and the Economic Substance Doctrine

    Substance v. Form Part III: Project Soy and the Economic Substance Doctrine
    2026/06/08

    In episode 54 of How Tax Works, Matt Foreman discusses the wonderfully-named Project Soy (Liberty Global v. U.S., No. 23-1410), the economic substance doctrine, GILTI, and why citing Helvering v. Gregory is rarely a good idea.

    How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, breaking down complex concepts for a clearer understanding of how tax laws impact your financial decisions.

    Follow us on Bluesky:
    @howtaxworks.bsky.social

    This podcast may be considered attorney advertising. This podcast is not presented for purposes of legal advice or for providing a legal opinion. Before any of the presenting attorneys can provide legal advice to any person or entity, and before an attorney-client relationship is formed, that attorney must have a signed fee agreement with a client setting forth the firm’s scope of representation and the fees that will be charged.

    This Podcast is Hosted by:
    Falcon Rappaport & Berkman LLP
    1185 Avenue of the Americas, Suite 1415
    New York, NY 10036
    (212) 203 -3255
    info@frblaw.com
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    28 分
  • Cannabis, 280E, and (sort of) Rescheduling

    Cannabis, 280E, and (sort of) Rescheduling
    2026/05/26

    In episode 53 of How Tax Works, Matt Foreman discusses the state of the taxation of Cannabis, how section 280E works, how to mitigate its effects, and why 471(c) isn’t a panacea.

    How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, breaking down complex concepts for a clearer understanding of how tax laws impact your financial decisions.

    Follow us on Bluesky:
    @howtaxworks.bsky.social

    This podcast may be considered attorney advertising. This podcast is not presented for purposes of legal advice or for providing a legal opinion. Before any of the presenting attorneys can provide legal advice to any person or entity, and before an attorney-client relationship is formed, that attorney must have a signed fee agreement with a client setting forth the firm’s scope of representation and the fees that will be charged.

    This Podcast is Hosted by:
    Falcon Rappaport & Berkman LLP
    1185 Avenue of the Americas, Suite 1415
    New York, NY 10036
    (212) 203 -3255
    info@frblaw.com
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    23 分