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IRS Amends Revenue Ruling 81-100 to Permit Participation in Group Trusts by Puerto Rico Plans and Insurance Company Separate...

The Internal Revenue Service (the “IRS”) issued Revenue Ruling 2014-24 (the “Ruling”). The Ruling amends Revenue Ruling 81-100, the ruling that established the requirements applicable to a tax-qualified group trust. The...more

IRS Finalizes Guidance on Rev. Rul. 81-100 Group Trusts, and Insurance Company Separate Accounts

In Rev. Rul. 2014-24, scheduled for publication on September 8, 2014, the Internal Revenue Service (the Service) substantially completed its pending guidance on Rev. Rul. 81-100 group trusts by permanently authorizing the...more

Florida DFS Unclaimed Property Grab “Clearly Erroneous”

Florida’s First District Court of Appeal filed an opinion yesterday in Thrivent Financial for Lutheran’s appeal from a declaratory statement issued by the Florida Department of Financial Services interpreting Florida’s...more

Florida Court Rejects "Date of Death" Trigger for Escheating Life Insurance Death Benefits Under Florida's Unclaimed Property Act

On August 5, Florida's First District Court of Appeal reversed a ruling issued by Florida's Department of Financial Services ("DFS") that would have triggered an insurer's duty to escheat life insurance benefits under...more

Give unto Caesar (but not a Dollar More!)-The Benefits and Planning Dexterity of the Charitable Lead Annuity Trust

Overview - I have to admit that I was a pretty good high school Latin student. In fact it may have been my best subject. When I got to West Point, I was in for very rude awakening. Not only did I realize too late that...more

Wealth Management Update - January 2014

January Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The January § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more

Plan sponsors should take stock of all plan amendments

I didn’t have such a wonderful time at law school because I felt the administration and much of the faculty weren’t honest when it came to the study of law and more importantly, our job opportunities. There was one law...more

Wealth Management Update - October 2013

The October § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 2.4%. This is up from September's 2.0% rate. The applicable federal rate ("AFR") for use with a sale to a defective...more

FDIC Insurance: Are Your Accounts Fully Covered?

When a client walks into a bank he or she is bombarded with signs indicating that the funds deposited in the bank are insured by the FDIC. Even if the client does not fully comprehend what that means, the signs offer the...more

Tales from the Crypt -- Post-Mortem Planning Using Private Placement Insurance Products

Overview - This article discusses the use of private placement products - private placement deferred variable annuities (PPVA) and private placement life insurance (PPLI)- in post mortem income tax and transfer tax...more

Wealth Management Update - May 2013

The May § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.2%, which is a slight decrease from April's rate of 1.4%. The applicable federal rate ("AFR") for use with a sale to a...more

The Family Loan Shark - Leveraging the AFR in the Taxpayer’s Favor Intra-Family Loans and Private Placement Insurance Products –...

Overview - High net worth and income taxpayers find themselves in a world of hurt following tax reform at the end of 2012. The top marginal bracket for taxpayers with more than $400,000 (single and $450,000 married)...more

New Rules Coming into Effect Affect Retirement Plans Entering into Swaps

New rules affecting ERISA-covered retirement plans entering into swap transactions will come into effect in May 2013. These rules, known as the “Business Conduct Standards,” implement certain provisions of the Dodd-Frank...more

IRS Releases Updated Retirement Plan Correction Procedures

The IRS recently released the long-awaited updated version of the Employee Plans Compliance Resolution System (EPCRS), Revenue Procedure 2013-12. EPCRS allows the sponsor of a tax-deferred retirement plan to voluntarily...more

Using the Family Investment Company to Access Your Pension Plan Assets

Overview - The wait is over. The taxpayer got dangled over the Fiscal Cliff and was allowed to have a controlled fall. For the high income taxpayer, the fall resulted in a broken ankle, bruised ribs and a minor...more

De-Risking Your U.S. Pension: Choices and Challenges

Defined benefit plan sponsors have become very focused on ways to control their asset volatility and to remove pension liabilities from their balance sheets. In fact, it would be fair to call “de-risking” a hot global issue...more

Using Private Placement Insurance Products to Achieve Tax Efficiency for High Net Worth

Originally published in the Journal of Taxation of Investments in December 2012. Introduction - This article is designed to provide an overview of the benefits of private placement life insurance (PPLI) and private...more

Rappelling Down the Fiscal Cliff – Strategies for Cushioning the Fall – Part I

Ready, set, go! Following the Presidential election last night, the race is on for year-end tax planning and bracing for the fall off the fiscal cliff. While no one can tell exactly what the tax outcome will be after...more

The Dynasty Annuity — Multi-Generational Tax Deferral for High-Net-Worth Families

Originally published in Tax Management Estates, Gifts, and Trusts Journal, x, 11/08/2012. OVERVIEW - The current tax environment suffers from a lot of economic and political uncertainty. The general consensus...more

In the Money – Deferred Compensation Planning for Hedge Fund Managers After IRC Sec 457A

Overview - The Emergency Economic Stabilization Act ended the not so well well-kept secret of hedge fund managers, the deferred compensation arrangement with their offshore funds or as the New York Times described, “an...more

The Super Roth IRA[1] - For Regular Guys (and Gals) - Part 2

Overview - In Part I of this series, I introduced the Super Roth IRA an alternative to the Roth IRA and traditional IRA. The Super Roth IRA uses the tax-advantages of permanent life insurance and is a more flexible...more

Here is Something to Whistle About!- Reflections on the UBS Whistleblower - Tax Reduction and Deferral Strategies for Trial...

Over the last few weeks I have been diligently outlining tax planning strategies for trial attorneys with contingent fee income. These strategies have ranged from structured settlement arrangements using private placement...more

Tax Reduction and Deferral Strategies for Trial Attorneys – Part 5 : Structured Settlement Life Insurance – A Tax-Free...

In Part 5, I focus on the utility of the QSF from an investment funding perspective to illustrate how private placement life insurance can be used in a split dollar life insurance funding format in order to to create a...more

Trial attorney - Tax Planning Using PPLI and CLATs (Supplemental Presentation)

Part I of this series focused on tax reduction and deferral strategies for trial attorneys with contingent fee income using private placement variable deferred annuities in lieu of fixed annuities for structured...more

Tax and Business Planning - August 2012

In This Issue: - Investment Income Surtax ...2 - Trusts and Estates ...3 - Increased Threshold for Deducting Medical Expenses ...3 - Planning Opportunities ... 4 Excerpt from Headline Article: Tax Increases...more

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