Polsinelli Podcast - Getting the Most Out of Your Estate Planning in 2014
The Greatest Gift: Your Individual + Family Estate Plan
The 2010 Tax Relief Act and your estate plan
Are your estate planning documents protecting your assets?
Same-Sex Marriage Cases in 90 Seconds
Should you Opt-Out of the Voluntary Disclosure Program?
Death and Foreign Asset Disclosure. What you don't know can cost you…a lot
Safeguard Your MVA: Devising a Business Succession Plan that will Preserve your Most Valuable Asset
Divorce can be costly, especially when it reveals undisclosed foreign assets.
Estate Planning: Wills, Trusts, & Power of Attorney in Arizona - Putting Family First
Foreign Asset Disclosure Program
Starsky had Hutch, Cagney had Lacey, Fred had Ginger, Bogie had Bacall, Bonnie had Clyde, Bert had Ernie, Baskin had Robbins, and Sheriff Bart had the Waco Kid. Whether it's law enforcement, entertainment, or any type of...more
Bermuda is a financial centre that is determined to grow, diversify, and improve upon the range and quality of the financial and professional services that it offers to its international clients.
This goal is supported...more
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
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’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
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
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
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
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
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
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
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
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
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 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
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
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
Originally published in the Journal of Taxation of Investments in December 2012.
This article is designed to provide an overview of the benefits of private placement life insurance (PPLI) and private...more
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
Originally published in Tax Management Estates, Gifts, and Trusts Journal, x, 11/08/2012.
The current tax environment suffers from a lot of economic and political uncertainty. The general consensus...more
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
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
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
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
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
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