Read our attorney Ron Lieberman’s answer as seen on NJMoneyHelp: If dad is on the mortgage, can he stop the sale of this home in divorce?

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Q. A couple bought a house and the husband’s father is on the mortgage because husband has bad credit. Fast forward a few years and the couple is divorcing. They want to sell the house and split the proceeds. Does the father on the mortgage have any say?

— Looking for help

A. You didn’t mention if your father-in-law is on the deed of the home.

 If your father-in-law is not on the deed, he is not an owner of the home, said Ronald Lieberman, an attorney and chair of the family law practice group at Cooper Levenson in Cherry Hill and Atlantic City.

“He has no rights to force or to prevent a sale,” Lieberman said. “In other words, he has all of the detriments of home ownership by being on the mortgage with none of the benefits of home ownership.”

Lieberman said upon the sale of the home, the mortgage would be paid off.

“A home cannot be sold unless any mortgages are satisfied by the sellers,” he said. “It should not matter to the father whether the proceeds from the sale pay off the mortgage or whether the sellers have to bring funds to the closing to pay off the mortgage because either way, the mortgage must be paid off and the father is cleared.”

As a result, Lieberman said, you can either sell or not sell the home, and your father-in-law has little if no ability to stop you.

Email your questions to Ask@NJMoneyHelp.com.

Make It Stop!-Can a Family Court Prevent a Party From Filing Applications?

“Make it stop!” is a familiar plea I hear from family law clients when an ex-spouse or partner files yet another application in Family Court. It can be extremely frustrating to be on the receiving end of the second, third, fourth….tenth….application. Post-judgment family actions can continue for years after the parties are divorced or initially resolved their issues (or so they thought). Especially if there are children in common, litigants will have many years of contact ahead of them.

Unfortunately for those on the receiving end of court filing after court filing, there is no bright line rule about how many times a party can file an application in Family Court. A court generally will not intervene to limit a party’s access to the court absent exceptional circumstances because it is a constitutional right under the Due Process Clause of the 14th Amendment of the United States Constitution. In the New Jersey Appellate Division case of Parish v. Parish, 412 N.J. Super. 39, 48 (App. Div. 2010), the Appellate Court held that a complete and blanket denial of a party’s access to the courts without regard for an application’s merits would be a denial of due process. However, all hope is not lost for litigants who feel they have been abused by frivolous or excessive court filings.

A court can, in some instances, limit a litigant’s access to it. But, before any prior restraint on access can be considered, the use of the litigation to harass must be first “objectively determinable.” D’Amore v. D’Amore, 186 N.J. Super. 525, 530 (App. Div. 1982). So, it has to be apparent to a reasonable observer that a claim is being made by one party to harass the other.

Many family law litigants feel they are being attacked or harassed merely because they are back in court, yet again. Still, that does not mean a court filing will rise to the level of harassment. For example, what if a party files an application seeking a change in parenting time, then three months later files an application to take advantage of the child tax credit, and then two months later files an application to compel the other party to contribute to the cost of extracurricular activities? The party on the receiving end of multiple court filings may feel such actions are taken to “get” that person, make him/her incur unnecessary fees or even, to harass. But without more, a reasonable observer likely could not determine that on their face, those filings were harassing in nature. Thus, the court would not limit a litigant’s access to it in those circumstances. And, before taking legally drastic measures to limit a party’s access to the court, a court could try to deter future filings by awarding counsel fees to the responding party or sanctioning the filing party.

Where a pattern of frivolous litigation can be demonstrated, a court can prevent an application from being filed when other available sanctions, such as monetary penalties, proved unsuccessful as a deterrent. Rosenblum v. Borough of Closter, 333 N.J. Super. 385 (App. Div. 2010).  In the event a restraint is imposed on a party, the restraint must apply to the “specifically identified claims which have been determined to fall within one of the recognized categories of objective harassment.” D’Amore, 186 N.J. Super. at 530. A court will not simply issue a blanket denial of a litigant’s access to it.

 

Stock Awards in a Divorce: Yours? Mine? It Depends…..

Oftentimes, you or your spouse receive stock awards from the employer. Those shares will vest over a period of years as opposed to all at once. The question then becomes, what happens to the stock awards which vest after a divorce complaint has been filed if the vesting depends upon you or your spouse’s efforts on the job after the filing? We know have an answer for you. The answer is…it depends.

A recent case from the Appellate Division now tells lawyers that they can argue that if the award was made during the marriage that their clients can keep them free and clear of the spouse’s claim if that stock was issued in whole or in part for future performance. In other words, the stock award must be made for services performed after the complaint for divorce was filed, for future services, and not a deferred compensation for prior efforts.

If you have stock awards, or you believe your spouse has them, you should find out if the stock was intended to vest due to future services and not prior services by looking at the stock plan and find out if the stock grants were designed to maintain a long term interest by the employee in the overall success of the company. Or, you need to determine whether the stock was intended to vest through mere continued employment without consideration of you or your spouse’s level of proficiency.

The Season of Giving (But Not Too Much)

by Alexandra Rigden, Esq., Family Law Practice Group

It’s that time of year again when everyone is focused on giving (and getting) presents. These words of advice may leave you feeling a bit chilly, but here are some caveats to remember about gift giving at the holidays:

If an engagement ends without a resulting marriage—regardless of who called the whole thing off—the giver of the ring is entitled to have it back in New Jersey, and in a majority of other States, because the ring was a “conditional gift” given on the condition a marriage would result. Keep in mind that after you get down on one knee to propose, you may end up on both knees begging for the ring back if you propose on Christmas or Hanukkah, for example. If the receiver wants to keep the ring, he or she could allege that the engagement ring was intended as an unconditional gift—no “I do” required. So, if you give an engagement ring on a traditional gift-giving holiday, it might be harder to refute that it was actually a conditional gift.

What happens to gifts given during the marriage in the event of a divorce? The important thing to remember in this instance is: what’s yours is ours. Marital gifts between spouses are subject to equitable distribution, regardless of who bought the gift and regardless of what was done with the gift. So, it matters not that the soon to be ex-spouse never drove the sports car she bought for her husband; it is still an asset subject to equitable distribution in the event of a divorce.

The moral of this holiday story is—gift wisely.

Self-Defeating Tweeting (and other social media pitfalls)

It’s too bad there isn’t some Miranda-type warning before posting on social media, something along the lines of: what you post online can and will be used against you in a (family) court of law. It seems elementary but it bears repeating: be careful what you post—whether it’s on Twitter, Facebook, Instagram, Snapchat, or even in text messages and emails. Messages and postings frequently end up being used in court filings and even during trials.

I have been involved in many cases where social media postings contribute to the undoing of a client’s case or the opposing party’s case. For example, if a parent claims he or she cannot afford to pay child support but posts on social media outlets about his or her vacations, meals out, and extravagant expenditures, it will undermine that person’s credibility. Incriminating online postings in cohabitation cases by an alimony recipient are also common social media pitfalls. If the alimony recipient claims he or she is not, for example, in a relationship recognized in the couple’s social and family circle (one of the factors for a finding of cohabitation, see N.J.S.A.  2A:34-23), but Facebook is littered with photos of family holiday celebrations, trips, and birthdays, with the new significant other, this information can and will be used against the alimony recipient in court and potentially hurt his or her case.

Another thing to keep in mind is whatever you text or email can end up in a court filing. Does it matter, legally, that ex-spouses/partners trade barbs via text message? Probably not. But, it does not paint the acrimonious and hostile party in a good light for the Court, and Judges are human, too. A party with reasonable positions and a credible and calm demeanor can be undermined by the other party introducing ugly and expletive-filled text messages.

Many clients ask “can he/she ACTUALLY use this stuff against me?” The answer is—absolutely. So, be careful.

Ronald G. Lieberman to speak at New Jersey State Bar Association Annual Meeting and Convention May 16 – 18

Atlantic City, N.J. — May 16, 2018 — Ronald G. Lieberman will speak at the New Jersey State Bar Association Annual Meeting and Convention on May 16, 17, and 18 at the Borgata in Atlantic City, N.J. The sessions include:

On Wed., May 16: “Is Alimony a Pension or Is There a Duty to Mitigate”
This session “looks to address the many practical issues surrounding whether a supported spouse has an affirmative duty to obtain gainful employment. While our case law allows for the imputation of income in appropriate circumstances is that a mere fiction? An obligor is required to work to capacity to support her ex-spouse, meaning she does not have the real option of hawking roses in the airport. Without a corresponding obligation imposed on the supported spouse are they not, in practical effect, permitted to hawk those roses in the airport if they choose? If income is imputed to a supported spouse should the courts upon a modification or retirement application factor into the analysis the monies representing possible bonuses, promotions and other career advancements? Should monies be imputed for the savings that would have or could have accumulated, whether in the form of retirement benefits or actual savings? In the end if there is no such duty then is alimony nothing more than a pension earned during the marriage?”

Presenters:
Moderator/Speaker: Paris P. Eliades, Esq., NJSBA Past President, Paris P. Eliades Law Firm LLC
Hon. Marie E. Lihotz, P.J.A.D. (Ret.), Archer Attorneys At Law
Hon. Angela White Dalton, J.S.C., Family Division, Monmouth County Superior Court
Hon. James A. Farber, J.S.C. (Ret.), Paris Eliades Law Firm, LLC
Ronald G. Lieberman, Esq., Cooper Levenson, Attorneys At Law
Frank A. Louis, Esq., Louis & Russell

On Thurs., May 17: “Would Equal Physical Custody Elevate a Parent’s Desires Over the Child’s Best Interests?”
This program explores whether exactly equal physical custody between parents elevates a parent’s desires over the fundamental underpinning of custody which is a child’s best interest. Social science and human conflict need to be reviewed to determine whether exactly equal physical custody is appropriate.

Presenters:
Moderator/Speaker: Ronald G. Lieberman, Esq., Cooper Levenson, Attorneys At Law
Hon. Terry Paul Bottinelli, J.S.C., Family Division, Bergen County Superior Court
Jeralyn L. Lawrence, Esq., Norris McLaughlin & Marcus
Megan S. Murray, Esq., Paone Zaleski & Murray
Amy Wechsler, Esq., Shimalla Wechsler, Lepp & D’Onofrio, LLP
Michael A. Weinberg, Esq., Archer Law

On Fri., May 18: “Family Law Bench-Bar Conference”
A discussion among experienced family law practitioners and family part judges on how we can work together to help resolve and adjudicate family law cases expeditiously. What do judges need from lawyers to help prepare them to hear a case and what lawyers need from judges to help them resolve their cases.

Presenters:
Moderator/Speaker: Sheryl J. Seiden, Esq., Seiden Family Law, LLC
Hon. Maritza D. Berdote Byrne, P.J.F.P., Presiding Judge, Family Division, Morris County Superior Court
Hon. Lisa F. Chrystal, P.J.F.P., Presiding Judge, Family Division, Union County Superior Court
Hon. Charles W. Dortch Jr., P.J.F.P., Presiding Judge, Family Division, Camden County Superior Court
Hon. Peter J. Melchionne, P.J.F.P., Presiding Judge, Family Division, Bergen County Superior Court
Hon. Marcella Matos Wilson, J.S.C, Family Division, Essex County Superior Court
Ronald G. Lieberman, Esq., Cooper Levenson, Attorneys At Law
Michael A. Weinberg, Esq., Archer Law

Cooper Levenson is a full service law firm since 1957, with 75 attorneys and New Jersey offices in Atlantic City and Cherry Hill. The firm also has offices in Bear, Del., Fort Lauderdale, Fla., and Las Vegas.

Is enforcing payment under religious agreement a “double-dip” if alimony is also awarded?

Written by Daria B. Janka, Esq. & Cynthia N. Grob, Esq.

Download the article PDF (Bulgarian)

American Courts increasingly must deal with how to treat shari’ah law in divorce proceedings.

To quote a Mhar Agreement: “This is a prompt Mahr: One gold coin, sum of money and jewelry to be given prior to marriage, sum of money deferred and to be paid upon the divorce of the parties. This contract is to be governed by Islamic Law.”

Did you know that the First Amendment might not preclude a Court from enforcing a Mahr agreement? How far have the Courts gone on to treat the agreement as a valid prenuptial agreement, or to nullify it, or to incorporate it as part of the equitable distribution division of the assets?

Mahr agreements are Islamic religious agreements entered into prior to marriage and are governed by Shari’ah law.  For many Muslims the Shari’ah is more than “law” it includes the methodology and process of ascertaining divine meaning and as such forms the moral and legal anchor of a Muslim’s existence.  In all interactions, under Shari’ah, a Muslim is governed by the same degree of honesty, good faith, an eye to fairness, social responsibility, and equity essentially they are to live an ethical life seeking to please God.

Many times Mahr agreements contain all elements of a secular contract between the parties.  Mahr is not a dower because it does not involve the bride’s father paying the groom but rather the groom must pay a price for the woman.  If they do not agree to a price, one will be determined by the Court.  In the bluntest terms, in the Islamic world, marriage is more of a contract than a sacrament. Islam emphasizes orthopraxis rather than orthodoxy and theology. The difficulty lies where a particular religion has developed an extensive system of laws.  Those laws govern marriage and divorce, alike.  Under New Jersey jurisprudence, it is a basic established principle that “a contract is a set of promises for the breach of which the law gives a remedy, or performance of which the law in some way recognizes as a duty.” Reinstatement (Second) of Contracts § 1 (1979).

The questions our Courts are faced with are what are Mahr agreements, what did the parties agree to, and is their contract enforceable?  Is a Mahr a prenuptial agreement?  Is it a simple contract?

In the New Jersey case of Odatalla v. Odatalla, 355 N.J. Super 305 (2002), the Court applied a two-prong test to determine whether a religious agreement is enforceable during divorce proceedings. Namely, is the contract: (1) capable of specific performance under “neutral principles of law” and (2) once those “neutral principles of law” are applied, does the agreement in question meet the state’s standards for those principles?  The trial court enforced the dower provision holding that applying neutral principles of law (i.e., the principals of contract law in New Jersey), the Mahr agreement satisfied the all of the elements of a valid civil contract. The court used the evidence adduced from a period prior to the contract to interpret the meaning of the words of the contract and concluded that the ten thousand dollar deferred portion of the Mahr was due upon the dissolution of the marriage under the contract. It is important to note that the Court equitably  distributed marital property, assets and debt and made findings as to alimony in the matter.

This New Jersey Court decision closely followed the New York Court decision in the case of Avitzur v. Avitzur, 58 N.Y.2d 108  (N.Y. 1993) addressing Jewish marital agreement. In Avitzur, the Court held there was nothing in law or public policy that prevented judicial recognition and enforcement of the secular terms of a religious marriage agreement because there was no excessive entanglement between church and state when the court applied neutral principles of contract law to decide the case.  This approach is consistent with Jones v. Wolf, 443 U.S. 595, 9 S. Ct. 3020 (1979) which explained that the “neutral principles of law” approach that allows agreements to be enforced based upon neutral principles of law as opposed to religious doctrine.

This approach, however, could run afoul of the parol evidence rule, which bars the introduction of extrinsic evidence to clarify the meaning of a contract, and is in essence rewriting agreements. The parol evidence rule of contract law stands for the principle that parol evidence cannot be introduced to create, vary or contradict a term of a contract not otherwise present in the written agreement. The overreaching use of parol evidence undermines the certainty of the contract and invites problems with the statute of frauds, which requires agreements to be in writing in order to be enforceable. The Odatalla Court, however, used an exception of the parol evidence rule, which stands for the preposition that evidence can be introduced to interpret the meaning of the written words of a contract.

            To avoid unnecessary confusion with regard to agreements which are likely to be enforced, you may want to contact an attorney to determine whether additional language should be included in your religious contract to avoid “double dipping”. We are taking the time to write about this to show you that entering into an agreement for religious purpose is far from a trivial question. You must understand how a religious agreement may affect your future rights. We, at Cooper Levenson, P.A., have earned a recognition as a specialized and experienced law firm in the representation of  clients in various areas, including contract and family law. 

Divorce Lawyers Know: One Size Does Not Fit All

by Ronald G. Lieberman, Esq.

As a family law/divorce attorney, I must be sensitive to my client’s backgrounds (cultural, economic, religious to name a few) . I must be sensitive to the fact that people from different cultures or religions may have a different view of marriage and divorce. I must listen to what you as the client are saying and also try to put things into the context of where you are from. Some divorces are not only about money and children but also about face and honor.

It’s up to me as the attorney to explain to clients what to expect based upon the legal system but also understand that the expectations of someone from one religious or cultural background may be different from that of another racial, ethnic, or religious background. I need to explain to clients that the legal system cannot solve one’s family problems.

I need to be sure to discuss whether to use the typical holidays or one of significance to someone who may be Islamic, Jewish, Hindu, or from some other religion with different holidays.  

You as the client should know that settlements are not be one-size-fits-all but should be based upon your particular needs and background. If you are worried about your child being removed from the United States and taken to another country where it will be impossible for the return of your child, then it is imperative to take protective measures. These issues should be explored carefully. If there is a religious aspect of a divorce such as an Islamic decree or a Jewish divorce or Get, these issues should be negotiated and put into writing so that there are no problems later on. Issues such as the religious upbringing of children and their schooling should be dealt with as well. If there is an issue of travel abroad with a child or children where there is family in another country, these issues should be covered. If there are issues involving a Green Card or citizenship or visas, it is important to find out the implications and deal with them. Sometimes it is important to have an opinion or intervention from an immigration attorney as well.

 Divorce is difficult, painful, and confusing, to say the least. If the client and I step back and work together, we can make the experience a little less painful.

Don’t Pay Your Lawyer For This

By: Alexandra K. Rigden, Esq.

Law is a business. So, this blog is actually against my financial interests because I am here to tell you what you should NOT pay your family law attorney to do:

  1. Referee day-to-day, ordinary parenting disputes: Fighting through lawyers over day-to-day, ordinary parenting disputes, can come with a high price tag, both emotionally and financially. When I say “day-to-day, ordinary parenting disputes”, I’m talking about, for example, mom feeding the kids non-organic instead of organic hot dogs; dad returning the children a few minutes late from parenting time; objections by one parent to other parent getting the child a haircut without prior consent—the list goes on and on. Parents will have to co-parent with each other long after the lawyers are gone. Sending the message during the litigation that day-to-day parenting decisions cannot be navigated without lawyers engenders acrimony and unnecessary fees. To the extent possible, parents should pick up the phone and try to figure it out.
  1. Act as your therapist: In the course of family law representation, I learn a lot about a client’s life. I may learn why their marriage broke up, why their kids are estranged from them, how their new relationship is going, how much they earn, and other personal—sometimes very personal—facts. Naturally, conversations transition from facts to feelings. As much as I do enjoy getting to know clients and understand the very human element to family law, I am a counselor at law, not a counselor at life. Moreover, in comparing hourly rates, most family lawyers are more expensive than therapists.
  1. Fight about ordinary personal property: I’m not talking about a Van Gogh painting or a Cartier watch…those items may well be worth the fight. I’m talking about tables, chairs, bed frames, mattresses, pots, pans…ordinary household items. Once these items were brought home they drastically depreciated in value. Your five-year-old mattress isn’t going to have much, or any, value on the open market. Paying lawyers to fight over ordinary personal property is not a wise use of your money.

4. Advise you about taxes and finances: I am not an accountant nor am I a financial advisor. Tax returns, tax issues, and finances are a daily part of a matrimonial practice. But, simply because a client’s finances are part of the equation, does not mean that a family lawyer is qualified to offer advice on them.

What the new tax law elimination of the alimony tax deduction means for divorcing and divorced couples

Authored by Cynthia N. Grob, Esq.  and  Jarad Stiles, Esq., LL.M.

A provision of the new tax law that took effect January 1, 2018 will have a substantial impact on divorcing couples.

The new law eliminates the alimony tax deduction and will impact agreements and judgments entered into after December 31, 2018.  Until December 31, 2018 and for all agreements entered into or judgments entered before that date, the old law applies.

To understand the impact going forward we first need to understand how the old law worked.  Under the old law, if the payor spouse was a high earner, he or she was subject to a higher tax bracket (especially if filing single) while the payee spouse was usually in a lower tax bracket.  This has the effect of shifting income from the individual payor in a higher tax bracket to the payee in a lower tax bracket.  This tax shifting typically justified a higher amount of alimony because the payor spouse is able to take a tax deduction which was not limited to phase-outs based upon income, like some other deductions, as it was an above-the-line deduction.

The elimination of this deduction will likely have a chilling effect on the amount of future alimony obligations as payor spouses and courts tasked with determining alimony obligations may reduce alimony paid as the tax deduction related to those payments has been eliminated.  The new tax law will impact cash flow for both payors and payees and it will take the assistance of tax professionals and matrimonial lawyers to help divorcing couples negotiate agreements that maintain parity between the amount of alimony paid under the old tax law and the amount paid under the new tax law.

The elimination of the alimony tax deduction along with the expansion of various tax brackets and rates necessitates a complex calculation of the impact on cash flow for both payors and payees.

For instance the new tax law poses a double whammy for payors filing as individuals earning $157,000 to $191,650 as under the 2017 tax brackets and rates those individuals were taxed at 28% rate and under the new tax law their tax rate will raise to 32%.  That individual will also lose the deduction related to alimony paid thereby reducing their cash flow by both.

Other changes under the new tax law that impact divorcing couples relate to the dependency exemptions related to children of the marriage which are eliminated under the new law which should serve to eliminate arguments over the same.

However, under the new tax law, the Child Tax Credit (CTC) has significantly increased.  Under old tax law, the CTC was worth up to $1,000 per qualifying child, was refundable for taxpayers with earned income of at least $3,000, and phased out (decreased) for taxpayers with AGI above $75,000 ($110,000 for joint filers). These rules remain in effect for 2017 tax returns (filed in 2018).  Under the new tax law the CTC is worth up to $2,000 per qualifying child. The age cut-off remains at 17 (the child must be under 17 at the end of the year for taxpayers to claim the credit).  Under the new law the beginning credit phase out for taxpayers does not occur until their AGI is above $200,000 ($400,000 for joint filers).

There are a few considerations that flow with the new CTC:

  • The refundable portion of the credit is limited to $1,400. This amount will be adjusted for inflation after 2018.
  • The earned income threshold for the refundable credit is lowered to $2,500.
  • The child must have a valid SSN to claim the nonrefundable and refundable credit.

Under the old law, the taxpayer who was eligible to claim the child’s dependent exemption was also the one eligible to claim the CTC. In turn, the taxpayer and child had to meet several “tests” for the one to be considered the dependent of the other.  The new eliminates the dependent exemption itself, but retains the definition of dependent to claim the CTC and other child- or dependent-related tax benefits.

For CTC purposes, this will usually mean that the child must be related to the taxpayer in one of several ways (son, daughter, grandchild, etc.), must live in the taxpayer’s home more than half the year, and must not provide more than half of his or her own support.

Generally, the custodial parent is the parent with whom the child lived for the longer period of time during the year.  However, the child will be treated as the qualifying child of the noncustodial parent if the special rule for children of divorced or separated parents (or parents who live apart) applies. See Publication 504, Divorced or Separated Individuals, for more information. This rule requires in part, that both of the following conditions are met:

  • The custodial parent signs a Form 8332, Release/Revocation of Release of Claim to Exemption for Child by Custodial Parent, or a substantially similar statement, and
  • The noncustodial parent attaches the Form 8332 or the statement to his or her return.

If the custodial parent releases a claim to exemption for a child, the noncustodial parent may claim the child as a qualifying child for the child tax credit. However, generally, the noncustodial parent may not claim head of household filing status or the earned income credit, and the noncustodial parent may not claim the credit for child and dependent care expenses, the exclusion for dependent care benefits, or the health coverage tax credit.

The elimination of the dependency exemption and the increase in the amount of the CTC as well as the amount of income a parent can earn before the CTC phase out begins from $75,000 to $200,000 will likely change the discussion for divorcing or separated individuals regarding these credits.  Again, they will likely require the assistance of both matrimonial attorneys and tax attorneys and professionals to calculate the impact on their cash flow that will result from the new tax laws.

Every tax payer’s situation is different. Depending on a myriad of factors certain tax payers may be subject to phase outs and the alternative minimum tax. Please see your tax professional for your specific situation.

For more information, see our tax legislation overview here.

Single Filers

Tax Bracket Tax Rate (2017) Proposed Bracket Proposed Tax Rate
$0 to $9,325 10% $0 to $9,525 10%
$9,325 to $37,950 15% $9,525 to $38,700 12%
$37,950 to $91,900 25% $38,700 to $82,500 22%
$91,900 to $191,650 28% $82,500 to $157,500 24%
$191,650 to $416,700 33% $157,500 to $200,000 32%
$416,700 to $418,400 35% $200,000 to $500,000 35%
$418,400 and above 39.6 $500,000 and above 37%

Married Filing Jointly

Tax Bracket Tax Rate (2017) Proposed Bracket Proposed Tax Rate
$0 to $18,650 10% $0 to $19,050 10%
$18,650 to $75,900 15% $19,050 to $77,400 12%
$75,900 to $153,100 25% $77,400 to $165,000 22%
$153,100 to $233,350 28% $165,000 to $315,000 24%
$233,350 to $416,700 33% $315,000 to $400,000 32%
$416,700 to $470,700 35% $400,000 to $600,000 35%
$470,700 and above 39.6 $600,000 and above 37%