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Use It or (Potentially) Lose It: Inflation Hikes Provide Unprecedented Estate Planning Opportunities

There are more estate planning opportunities as a result of inflation-adjusted figures recently released by the IRS. The gift, estate, and generation-skipping transfer (“GST”) tax exemption amounts are each increasing to...more

FinCEN Corporate Transparency Proposed Regulations: Beneficial Ownership Information Reporting Requirements and the Potential...

On December 7, 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) proposed new regulations (“Proposed Regulations”) defining and implementing the beneficial ownership reporting...more

THE TIME TO ACT IS NOW – House Ways and Means Committee Proposes Tax Changes: Significant Provisions Related to Estate Planning...

On September 13, 2021, the House Ways and Means Committee formally released its proposed tax provisions to be incorporated into the broader budget reconciliation bill it hopes will pass in the near future (the “Tax...more

Estate Planning in a COVID-19 Environment and Relevant CARES Act Relief Provisions

As each of us copes with the ongoing challenges posed by COVID-19, we hope this finds you and your families safe and healthy. It can be difficult to think beyond the moment when faced with the daily anxiety and uncertainty...more

IRS Issues Regulations Clarifying Opportunity Zones and Opportunity Funds

The Opportunity Zone program created by the Tax Cuts and Jobs Act of 2017 (the “TCJA”) allows taxpayers that realize certain gains to elect to defer the federal income tax on such gains by reinvesting them into Qualified...more

State Tax Update for Delaware Corporations

While the State of Delaware has numerous attractive aspects for entities that incorporate there (a flexible corporation statute, the well-respected Court of Chancery, a legislature that prioritizes the stability of Delaware’s...more

Partnership Audits of Private Equity Firms on the Rise

There has been buzz in the tax and private equity communities about the rise in audits of private equity firms by the Internal Revenue Service (“IRS”). This has been fueled by the restructuring of the IRS’ Large Business &...more

New Foreign Equivalency Determination Regulations

The IRS released final regulations under Internal Revenue Code Sections 4942 and 4945 on September 25, 2015, specifically addressing grants by private foundations to foreign organizations. These final regulations are partly...more

Publicly Traded Partnership Proposed Regulations

Widely held partnerships are a significant source of funding for oil, gas and certain natural resources projects, but the publicly traded partnership (“PTP”) rules can cause such partnerships to be treated as corporations for...more

US Energy Excise Tax Proposed Legislative Changes

Federal excise taxes imposed on natural gas, propane and other alternative fuels can significantly add to their cost and can create a disincentive to their use compared with more traditional fuels such as diesel and gasoline,...more

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