LA Wildfires Relief Resources: A Comprehensive Guide for Affected Homeowners
This guide provides comprehensive information about financial, insurance, and tax relief available to victims of the Los Angeles wildfires. Key relief measures include extended tax deadlines, property tax reassessment options, federal disaster assistance, and various insurance claim procedures. Throughout this document, we highlight the most time-sensitive actions you should take and explain complex tax concepts that may affect your recovery process.
Immediate Financial and Liquidity Needs
Wildfire victims may be able to access an upfront claim payment from their insurance.
Disaster loans, lines of credit, or other loans may be available to cover immediate expenses. You can speak with your financial advisor about a line of credit secured by your investments.
Disaster assistance may be available from the Federal Emergency Management Agency (FEMA), which can help with temporary housing, home repairs, and other needs. You can get information from FEMA's website or by calling their helpline after a federally declared disaster.
Low-interest loans may be available from the Small Business Administration (SBA) to repair or replace damaged property, even for individual homeowners.
Assistance may be available from local charities, nonprofits, and community organizations. Some organizations provide grants or direct financial assistance. Goldman Sachs has identified organizations providing assistance to Los Angeles residents.
Employers may provide assistance to their employees, including penalty-free retirement plan distribution options and charitable relief funds.
The SECURE 2.0 Act of 2022 created easier access to retirement assets for victims of federally declared disasters, including relaxed loan, distribution, and repayment rules. You can contact your advisor for further information.
Insurance Claim Process
Contact your insurance company immediately as soon as it is safe to do so. Most insurers have 24/7 claims hotlines or online portals.
Submit a proof of loss claim, which should include an itemized list of damaged or lost items along with their values.
Document all damages with pictures and video, as safety allows. Save a portion of the damaged property when possible.
Keep detailed records of all expenses and retain receipts, including temporary housing and additional living expenses, which might be covered under your policy's "Additional Living Expenses" (ALE) coverage. Insist on detailed invoices for all loss expenses.
Avoid premature guesses, overly optimistic evaluations, or quick settlements.
Leverage other resources like pre-disaster photos and videos, and statements from banks and credit card companies to help create an inventory of lost or damaged items. For improvements to real property, contact contractors for copies of invoices.
The California Department of Insurance offers guidance on insurance claims and recovery after a wildfire.
California FAIR Plan
The FAIR Plan is a state-mandated insurance program providing basic property insurance to those unable to obtain coverage in the traditional market, often in high-risk areas like those prone to wildfires.
It offers basic fire insurance coverage for fire, lightning, and internal explosion but does not provide comprehensive homeowners insurance covering perils like theft, liability, water damage, or earthquake. Policyholders may need to purchase a "Difference in Conditions" (DIC) policy for additional coverage.
Premiums for the FAIR Plan may be higher than standard insurance policies because it is designed for high-risk properties.
It is important to work with an experienced insurance broker or agent who understands the complexities of insuring high-risk properties to navigate available options and tailor coverage.
Federal Tax Relief
The IRS has announced comprehensive tax relief for victims of the Los Angeles County fires that began on January 7, 2025.
Certain deadlines falling on or after January 7, 2025, and before October 15, 2025, are granted additional time to file, with a new deadline of October 15, 2025, to file returns and pay any taxes originally due during this period. This includes:
Individual income tax returns and payments normally due on April 15, 2025
2024 contributions to IRAs and health savings accounts
Quarterly estimated income tax payments
Entity returns (e.g., partnership, corporation, trust)
Taxpayers who suffer loss, damage, or destruction of real or personal property due to a disaster like wildfires may be eligible for a casualty loss deduction on their federal tax return. This deduction is generally for losses attributable to a federally declared disaster for tax years 2018 through 2025.
The amount of the casualty loss is the lesser of the adjusted basis of your property or the decrease in fair market value because of the casualty, reduced by salvage value and any insurance or other reimbursement. Further reductions may apply. Adjusted basis refers to the original cost of the property plus any improvements minus depreciation. For example, if you bought a home for $500,000 and spent $50,000 on a kitchen remodel, your adjusted basis would be $550,000 (minus any depreciation if applicable).
For federally declared disasters, a special rule may allow you to claim the loss in the tax year preceding the casualty and receive a refund sooner. This election is typically made on Form 4684.
Qualified disaster losses, attributable to major disasters declared by the President between January 10, 2020, and February 10, 2025 (with the incident period between December 28, 2019, and January 11, 2025), have a $500 per-event limit and need not be itemized, potentially increasing the standard deduction using Schedule A (Form 1040). There is some ongoing uncertainty regarding the application of this to the LA fires given the timeline, and further clarification is expected. However, absent further clarification, the LA County Wildfires are not considered qualified disaster losses.
Qualified wildfire relief payments received between 2020 and 2025 following a wildfire disaster are not taxable to the extent your losses, expenses, or damages compensated by these payments were not otherwise reimbursed by insurance. These include payments for:
Additional living expenses
Lost wages (not paid by your employer)
Personal injury or death
Emotional distress
You cannot take a deduction or increase your basis for expenses compensated by these payments.
In some cases, the IRS may allow penalty-free early withdrawals from retirement accounts for those affected by disasters, although taxes on the withdrawals may still apply. The SECURE 2.0 Act has also relaxed rules regarding retirement plan loans for disaster victims.
Taxpayers can amend a previous year's tax return on Form 1040-X to take advantage of disaster-related relief.
Federal disaster relief grants received under the Stafford Act are generally not included in your income if the payments help meet necessary expenses or serious needs.
California State and Local Tax Relief
Extended State Tax Deadlines: California has also granted taxpayers in LA County an extension to file and make payments (until October 15, 2025) due between January 7 and October 15, 2025, aligning with the federal relief.
Property Tax Relief (Temporary Property Tax Reduction/Calamity Reassessment): You may be eligible for a temporary reduction in your property tax assessment if your home has suffered damage of $10,000 or more due to the wildfire. You must:
File a claim (Form ADS-820 in Los Angeles County) with your county assessor's office within 12 months of the date of loss, although filing sooner is advisable
The property will be reassessed to reflect its reduced value, lowering your property taxes until it is repaired or rebuilt
After repair or rebuilding (if substantially equivalent), the assessment can be restored to its pre-disaster level, adjusted for inflation
Property Tax Deadline Extension: Governor Newsom has extended the deadline for 2025 property taxes to April 10, 2026, for those in specified Los Angeles County zip codes affected by the fires. To ensure the reduced amount is due in 2026, taxpayers should file the calamity reassessment form now.
Proposition 19 (Transfer of Property Tax Base): Eligible homeowners can transfer the taxable value of their original primary residence to a new home anywhere in California if their home was damaged or destroyed by a wildfire. Taxable value refers to the assessed value used to calculate property taxes, which is often lower than market value due to California's Proposition 13 limitations. For example, if you purchased your home in 1990 for $200,000, your taxable value might still be around $300,000 even if the market value is $1 million. Key points include:
No limit on the number of times wildfire victims can use this benefit
The replacement home can be of equal or lesser value to maintain the same tax base
If the replacement home is of greater value, the difference will be added to the transferred taxable value
This applies even if you move to a different county
Under R&TC §69.6, if the replacement property in the same county has a market value equal to or greater than the original, you must sell the original property to qualify
State Income Tax Deductions: Similar to federal relief, California allows for state income tax deductions for disaster-related casualty losses, claimed on California Form 4684. Taxpayers may be able to choose between 2024 and 2025 for deducting their California loss.
Fee Waivers and Other Assistance: The state may offer additional assistance, such as waivers of certain fees or penalties related to tax filings and payments for affected individuals and businesses.
Los Angeles County may also offer delayed filing for sales and use taxes for affected taxpayers.
Other Important Relief and Resources
Replacing Lost Documents: Begin the process to replace critical lost documents like passports, birth certificates, and car titles. Contact relevant agencies like Vital Records, the DMV, and the State Department for information on replacement procedures and potential fee waivers for major disasters.
Mental Health Support: Prioritize mental health and utilize resources like community counseling, support groups, and the federal Disaster Distress Helpline.
Community Rebuilding: Various organizations are providing assistance for rebuilding efforts in Los Angeles.
Online Resources:
The JPMC natural disaster landing page provides information, contact details for FEMA and the Red Cross, a link to file an insurance claim, and FAQs
The California State Board of Equalization (BOE) provides information on property tax relief and Proposition 19
County Assessor's Offices (like Los Angeles County Assessor) provide specific forms and information for calamity reassessment
Cal OES and other agencies also offer recovery resources
Financial Advisor Assistance: Your financial advisor can help navigate financial challenges, develop rebuilding plans, adjust long-term financial goals, offer emotional support, and connect you with other resources like legal and tax advisors and government programs.
Tax Professional Consultation: It is crucial to consult with tax professionals or directly with the IRS and California FTB to understand the specific relief options available to you and ensure you meet all eligibility requirements.
It is important to continuously check for updated guidelines and relief measures from federal, state, and local authorities.
Property Tax Relief
California offers several property tax base transfer rules to assist victims of disasters, such as the Los Angeles wildfires. These rules allow eligible homeowners and sometimes other property owners to transfer the taxable value (base-year value) of their damaged or destroyed property to a replacement property, potentially providing significant property tax savings.
Temporary Reduction in Property Taxes: Calamity Reassessment
California law allows for a temporary reduction in property taxes when a property has suffered damage of $10,000 or more due to a calamity such as a wildfire. This is known as a “calamity reassessment".
Eligibility: If your property has sustained significant damage from the wildfires, you may be eligible for a temporary reduction in your property tax assessment.
Application Process: To request a reassessment, you must file a claim with the Los Angeles County Assessor's office. This typically involves submitting a form and providing evidence of the damage, such as repair estimates or insurance claims. It is advisable to file this claim as soon as possible, although you generally have up to 12 months from the date of loss to do so. You can find specific information and forms on the Los Angeles County Assessor's Office website. Remember to also update your address with the County Assessor by filing Form ASSR-451.
Reassessment: Once your application is approved, the County Assessor will reassess your property to reflect its reduced market value due to the damage. This lowered assessment will result in reduced property taxes until the property is repaired or rebuilt.
Restoration and Rebuilding: After you repair or rebuild your home in a way that is substantially equivalent to the original property, the property will be reassessed to its pre-disaster value, adjusted for inflation.
Time Limits: Be aware that there are time limits for filing a calamity reassessment claim, often within a year of the disaster. However, it is prudent to file sooner rather than later given the volume of properties requiring reassessment.
Transfer of Property Tax Base: Proposition 19
Proposition 19 offers significant property tax benefits to homeowners whose primary residences have been damaged or destroyed by wildfire or natural disaster. It allows eligible homeowners to transfer the taxable value of their original primary residence to a new replacement home.
Statewide Application: Unlike previous rules, Prop 19 allows this transfer to occur anywhere within the state of California.
Replacement Home: The replacement home can be of equal or lesser value to the original home to maintain the same tax base. If the replacement home is of greater value, the difference in value will be added to the original taxable value, potentially resulting in a higher, but still potentially reduced, property tax.
Flexibility for Wildfire Victims: Notably, for victims of wildfire or natural disaster, there is no limit on the number of times they can transfer their taxable value. This provides significant flexibility for those needing to relocate due to disaster-related circumstances.'
Example: If your original home had a taxable value of $300,000 and a market value of $800,000 before being destroyed, and you purchase a new home for $900,000, you may be able to transfer the $300,000 taxable value to the new property. Your property taxes would then be based on the $300,000 plus the $100,000 difference in market value.
Sale of Original Property: Under the implementing statute for Proposition 19 (R&TC §69.6), the taxpayer must sell the original property to qualify for the base-year value transfer to a replacement property in any county.
Base-Year Value Transfer: Other Options (R&TC §69 and §69.3)
Beyond Proposition 19, other provisions may offer base-year value transfer relief under different circumstances.
Transfer Within the Same County (R&TC §69): Taxpayers can transfer the base-year value of any substantially damaged (50% of market value reduction) real property to any comparable property in the same county. This applies to all real property, including manufactured homes and business property, and the damaged property does not need to be sold. The replacement property must generally be purchased or newly constructed within five years from the date of the Governor-proclaimed disaster.
Transfer to Another County (R&TC §69.3): If you choose to replace your substantially damaged or destroyed principal residence with a property in another California county that has authorized intercounty base-year value transfers, you may be eligible under R&TC §69.3. Currently, 14 counties have authorized this transfer, including Los Angeles County itself, Contra Costa, Glenn, Modoc, Orange, San Diego, San Francisco, Santa Clara, Solano, Sonoma, Sutter, Ventura, Yolo, and Yuba. Under this section, the replacement property must generally be purchased within three years from the date of the Governor-proclaimed disaster, and the original damaged property does not need to be sold. The replacement property's market value must be equal to or lesser than the original property's market value.
Important Considerations and Next Steps
It is crucial to understand the specific requirements and deadlines associated with each of these relief options.
You may be eligible for more than one type of property tax relief, and it is important to determine which option best suits your individual circumstances.
We strongly encourage you to consult with your tax advisor to discuss your specific situation and ensure you take the necessary steps to maximize available property tax relief.
Remember to stay informed about any further updates or clarifications issued by the County Assessor's office and the California State Board of Equalization.
Update Addresses: File Form ASSR-451 with the County Assessor and update your address with the FTB and IRS to ensure you receive important notices and relief information. Businesses should also update their addresses with the EDD and CDTFA.
Our firm is dedicated to assisting you through this challenging time. Please do not hesitate to reach out to us if you have any questions or require legal assistance in navigating these property tax relief options.
Tax Treatment of Insurance Proceeds
Following the devastating wildfires in Los Angeles County, we understand that many of you are navigating the complex process of insurance claims and financial recovery. A key aspect of this process is understanding the tax treatment of insurance proceeds received for property damage and other losses. This newsletter aims to provide clarity on these important considerations under federal and California law.
General Principles: Reimbursement and Gain/Loss
Generally, when you receive insurance proceeds as a result of damage or destruction to your property from the wildfires, these payments are intended to make you whole and are often not considered taxable income. However, the tax implications can vary depending on whether the proceeds exceed your adjusted basis in the damaged property, are less than your loss, or cover specific types of expenses.
Proceeds Exceeding Basis: Potential for Gain: If the insurance proceeds you receive are more than your adjusted basis (your original cost plus improvements, minus depreciation) in the destroyed property, you may realize a gain.
However, you may be able to postpone reporting this gain if you reinvest the insurance proceeds in qualified replacement property within a certain period. The replacement period is generally two years from the end of the tax year in which you realize the gain, but this period may be extended to four years if the principal residence was in a federally declared disaster area. To postpone the entire gain, the cost of the replacement property must be at least as much as the reimbursement you receive. If the replacement cost is less, you will have to include the unspent portion of the reimbursement in your income.
If your principal residence was destroyed in a federally declared disaster and you choose to relocate and sell the underlying land, the destruction and sale are treated as a single involuntary conversion. Involuntary conversion refers to the loss of property through events like fire, theft, or condemnation, rather than voluntary sale. This legal classification provides specific tax treatment options.
It's important to note that you cannot postpone reporting a gain if you buy the replacement property from a related person.
Proceeds Less Than Loss: Impact on Casualty Loss Deduction: If the insurance proceeds do not fully cover your loss, the unreimbursed portion may be eligible for a casualty loss deduction, particularly if the loss is attributable to a federally declared disaster.
The amount of the casualty loss is generally the lesser of your adjusted basis in the property or the decrease in its fair market value due to the casualty, reduced by any insurance proceeds or other reimbursements you receive or expect to receive. This amount is further reduced by $100 per casualty event and the total net loss is deductible only to the extent it exceeds 10% of your adjusted gross income (AGI). Adjusted gross income (AGI) is your total income minus specific deductions like retirement contributions, but not including itemized deductions.
However, for qualified disaster losses (personal casualty losses attributable to certain major federally declared disasters), the per-event limit was previously $500, and the deduction did not need to be itemized. It is advisable to confirm the specific rules applicable to the Los Angeles wildfires with your tax advisor, as there has been concern regarding the 10% AGI limitation.
You must generally deduct a casualty loss in the tax year in which the casualty occurred. However, if the loss occurred in a federally declared disaster area, you can elect to deduct that loss on your return or amended return for the tax year immediately preceding the disaster year. For the Los Angeles County fires that began on January 7, 2025, you generally have until October 15, 2025, to amend your 2024 return to claim the loss.
Insurance for Living Expenses: Insurance payments you receive to cover living expenses due to being displaced by the wildfire generally do not reduce your casualty loss. These payments are often considered separate from the compensation for the damaged or destroyed property itself.
Qualified Wildfire Relief Payments
Certain relief payments received between 2020 and 2025 following a wildfire disaster are not taxable to the extent your losses, expenses, or damages compensated by these payments were not otherwise compensated by insurance or other reimbursement. These qualified wildfire relief payments can include amounts for additional living expenses, lost wages (not paid by your employer), personal injury or death, or emotional distress. You cannot take a credit or deduction for any expense compensated by a qualified wildfire relief payment.
Important Considerations and Next Steps
Document Everything: Keep meticulous records of all insurance communications, payments received, and expenses related to the wildfire damage and recovery.
Adjusted Basis: Accurately determining your adjusted basis in the damaged property is crucial for calculating potential gains or losses.
Replacement Property: If you plan to reinvest insurance proceeds, understand the deadlines and requirements for qualified replacement property.
State Tax Implications: California has its own rules regarding casualty losses, and you may need to file a separate Form 4684 with the California Franchise Tax Board (FTB). California also generally aligns with the federal relief regarding the taxability of reimbursements for federally declared disasters.
The tax treatment of insurance proceeds and wildfire-related losses can be intricate. We strongly encourage you to consult with your tax advisor to discuss your specific circumstances and ensure you are taking the appropriate steps to comply with federal and California tax laws. Our team is here to support you through this process. Please do not hesitate to reach out with any questions or if you require further assistance.
Casualty Loss/Gain and Involuntary Conversion
Following the devastating Los Angeles County wildfires, this newsletter provides important guidance on calculating casualty loss deductions or gains and understanding the rules for deferring gains from involuntary conversions, both of which are critical tax considerations for affected individuals. We will also address whether purchasing a home requiring construction qualifies as replacement property.
Calculating Casualty Loss Deductions and Gains
Both federal and California law allow deductions for casualty losses resulting from federally declared disasters like the LA County wildfires. However, the calculation and limitations differ:
Federal Rules
For personal-use property, the deductible loss is the lesser of your adjusted basis in the property or the decrease in its fair market value (FMV) due to the casualty, reduced by any insurance or other reimbursements received or expected. Salvage value also reduces the loss.
This amount is further reduced by $100 per casualty event. However, for a qualified disaster loss, the per-event reduction is $500. It's important to note there is ongoing concern whether the Los Angeles fires' signature dates will fully align with the requirements for qualified disaster loss treatment.
The remaining loss is deductible only to the extent it exceeds 10% of your Adjusted Gross Income (AGI). However, this 10% AGI limitation does not apply to qualified disaster losses.
You generally report casualty losses on Form 4684, Casualties and Thefts.
If insurance or other reimbursements exceed your adjusted basis in the destroyed property, you have a gain. This gain is generally included in your income in the year you receive the reimbursement, unless you choose to postpone reporting it under the involuntary conversion rules discussed below.
California Rules
California also allows state income tax deductions for disaster-related casualty losses.
While California generally aligns with federal rules regarding the initial calculation of the loss (lesser of basis or FMV decrease, reduced by reimbursements), the 10% of AGI limitation does apply for California tax purposes.
Governor Newsom indicated that taxpayers may choose to deduct their California loss in 2024 or 2025.
California has its own Form 4684 for claiming disaster losses.
Deferring Gain from Involuntary Conversions
If your principal residence is destroyed in a federally declared disaster (like the Los Angeles fires), and you choose to relocate and sell the underlying land, the destruction and sale are treated as a single involuntary conversion for federal income tax purposes. This means that the tax implications are governed by the rules for involuntary conversions, which can offer certain tax relief.
General Rules For Involuntary Conversions
Treatment as a Single Event: The IRS treats the destruction of your home and the subsequent sale of the land as one event -- an involuntary conversion. This is important for determining how any gains or losses are handled for tax purposes.
If you realize a gain because insurance or other proceeds exceed your adjusted basis in property destroyed in the wildfires, you may be able to postpone reporting the gain under the involuntary conversion rules of Section 1033 of the Internal Revenue Code. This generally applies if you reinvest the reimbursement in replacement property within a specified period.
Replacement Period: For a main home located in a federally declared disaster area, the replacement period generally ends four years after the close of the first tax year in which any part of the gain is realized. For other property, the replacement period is generally two years after the close of the first tax year in which any part of the gain is realized. For the Los Angeles wildfires that began in January 2025, the replacement period for a main home could potentially extend until December 31, 2029, for a calendar year taxpayer who realizes a gain in 2025.
Amount of Gain Postponed: To postpone the entire gain, the cost of the replacement property must be at least as much as the reimbursement you receive. If the cost of the replacement property is less than the reimbursement, you must include the gain in your income up to the amount of the unspent reimbursement.
Like-Kind Replacement: Generally, the replacement property must be similar or related in service or use to the destroyed property. However, for business or income-producing property located in a federally declared disaster area, any tangible replacement property acquired for use in any business is treated as similar or related in service or use. For an owner-user of a principal residence, the replacement property must also be used as your home.
Replacement Property and Construction Costs
Purchasing a home that requires construction can qualify as replacement property for the involuntary conversion rules. The cost of the replacement property includes the total cost of the new home, including construction costs incurred within the replacement period.
Tracking Costs: It is crucial to keep detailed records of all construction costs, including contracts, invoices, and payment records, to substantiate the amount reinvested.
Timeline: The construction must be completed within the replacement period to qualify for full deferral of the gain.
Interaction with Casualty Loss Deduction
Even though the event is treated as an involuntary conversion, you will still likely calculate a casualty loss for the destruction of your home as we discussed previously. The insurance proceeds you receive will reduce the amount of this loss.
If your insurance proceeds are less than your adjusted basis, you may have a deductible casualty loss, subject to the $100 reduction and the 10% of Adjusted Gross Income (AGI) limitation for federal taxes.
If your insurance proceeds exceed your adjusted basis, you may have a gain from the involuntary conversion. This is where the reinvestment rules for involuntary conversions become particularly relevant for potentially deferring the tax on this gain.
Exclusion of Gain on Principal Residence'
The general rules for the exclusion of gain on the sale of a principal residence (section 121 of the Internal Revenue Code) may also come into play. Under these rules, you can exclude up to $250,000 of gain ($500,000 for married couples filing jointly) from the sale of a home you have owned and used as your main home for at least two of the five years before the sale.
In the context of an involuntary conversion due to a federally declared disaster, there are often exceptions and extensions to these "ownership and use" requirements. You should consult with your tax advisor to discuss your particular situation and the associated IRS guidance if this is applicable to you. The exclusion might apply to any gain realized from the insurance proceeds exceeding your basis, potentially further reducing or eliminating any taxable gain, even if you don't reinvest all the proceeds.
As we discussed earlier, insurance payments and certain federal and state disaster relief payments you receive for the destruction of your home are generally tax-free. These payments will, however, reduce the amount of your casualty loss.
Important Considerations and Next Steps
Document Everything: Thoroughly document all damages with photographs and detailed notes, and keep meticulous records of all expenses and insurance communications.
Consult Your Insurance Provider: Work closely with your insurance company throughout the claims process.
Consider Property Tax Relief: Explore California's property tax relief measures, such as calamity reassessment and the transfer of your property tax base under Proposition 19. Remember to file Form ADS-820 for calamity reassessment with the Los Angeles County Assessor.
Update Your Address: File Form ASSR-451 with the County Assessor and update your address with the FTB and IRS to ensure you receive important notices.
Seek Professional Advice: Given the complexities of these rules, it is essential to consult with your tax advisor to determine the specific treatment applicable to your situation and ensure compliance.
Our firm is committed to supporting our clients through the recovery process. Please do not hesitate to reach out if you have any questions or require personalized assistance.
About the Author
Jordan Toplitzky is a CPA, a member of the AICPA, and earned an MBA from the University of Michigan and a Master of Business Taxation from the University of Southern California.
Jordan began his career as a CPA serving ultra-high net worth individuals and their closely-held businesses at Andersen. He has helped companies raise debt and equity capital, led companies through two successful exits, and scaled businesses for 100%+ year over year growth. He has devised estate transfer plans and structured investment and business transactions that attained significant tax savings and guided clients’ finances to sustained growth.
Jordan was the Audit Committee Chair on the Board of Directors of Ceres Acquisition Corp., a publicly listed SPAC, and is involved in various philanthropies, including at his alma mater the University of Michigan, Ann Arbor, and Jewish Big Brothers Big Sisters of Los Angeles. He currently serves as the Audit Committee Chair of Campbell Hall Episcopal School.
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This Toplitzky&Co publication provides information and comments on tax issues and developments of interest to our clients and friends. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide tax advice. Readers should seek specific tax advice before taking any action with respect to the matters discussed herein.
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