Question
I read in both your most recent letter (July 2016) and in your April 2015 letter that the sale of personal goodwill would be subject to the net investment income tax (3.8 percent).
In the May 2016 issue of the Tax Advisor published by the AICPA, there is an article titled “Personal Goodwill and the Net Investment Income Tax.” I hope to obtain your stance on the goodwill issue, as it seems that an argument can be made for excluding the capital gain attributable to personally generated goodwill from the net investment income tax calculation, as described in the Tax Advisor article.
If you have considered the Tax Advisor article, I would appreciate your thoughts. ... Log in to view full article.