Wills, Trusts, & Estate Planning, Insurance, Finance & Banking

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

by Gerald Nowotny on 5/9/2013

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

by Maggie Mouradian | Proskauer Rose LLP on 5/3/2013

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 –...

by Gerald Nowotny on 3/13/2013

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

by King & Spalding on 2/5/2013

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

by Harry Atlas, Jessica Kuester, Lisa Tavares | Venable LLP on 1/23/2013

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

by Gerald Nowotny on 1/14/2013

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

by Carol Buckmann | Osler, Hoskin & Harcourt LLP on 12/11/2012

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

by Gerald Nowotny on 12/3/2012

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

by Gerald Nowotny on 11/9/2012

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

by Gerald Nowotny on 11/5/2012

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

by Gerald Nowotny on 10/18/2012

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

by Gerald Nowotny on 10/15/2012

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...

by Gerald Nowotny on 10/8/2012

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...

by Gerald Nowotny on 10/1/2012

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)

by Gerald Nowotny on 9/25/2012

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

by Polsinelli on 8/7/2012

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

Frozen Cash Value Life Insurance - A sophisticated tax planning solution for ultra-high-net-worth taxpayers

by Gerald Nowotny on 7/31/2012

Originally published in Trusts & Estates/Wealthmanagement.com - July 2012. Frozen cash value (FCV) is best known as a private placement flexible premium variable adjustable (universal) life insurance policy that’s issued...more

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

by Gerald Nowotny on 7/25/2012

Originally published in Journal Of Taxation Of Investments - Summer 2012. Although no one can predict what Congress will do at any point, it is quite likely we will see higher income tax rates in the near future, along...more

Delaware Federal Court Issues Important Post-Price Dawe Opinion

by Orrick, Herrington & Sutcliffe LLP on 7/18/2012

In a memorandum opinion issued in Principal Life Insurance Company v. Lawrence Rucker 2007 Insurance Trust on June 26, 2012, a federal district court applied the Delaware Supreme Court’s holding in PHL Variable Life Insurance...more

FDIC Reveals Banks’ Living Wills

by BuckleySandler LLP on 7/11/2012

On July 3, the Federal Deposit Insurance Corporation (FDIC) posted the public sections of the initial resolution plans submitted by sixteen large bank holding companies. ...more

Living Wills: Public Portions Released

by Morrison & Foerster LLP on 7/6/2012

Banking organizations required to file resolution plans, or “living wills,” received some additional instruction this past Tuesday, July 3, 2012, when the Federal Deposit Insurance Corporation (“FDIC”) and the Federal Reserve...more

Life Insurance Proceeds Paid To A Trust Are Not Subject To Creditor Claims

by Rowley Chapman & Barney, Ltd. on 4/15/2012

The Arizona Court of Appeals recently held in the case In Re King, that even though the debts of the decedent were greater than her assets at death, the life insurance proceeds, payable to her trust created prior to her...more

Insight on Estate Planning - April/May 2012

by Adler Pollock & Sheehan P.C. on 4/1/2012

In This Issue: - Make health care decisions while you’re healthy - Which planning strategies should unmarried couples implement? - Due diligence required when taking charitable deductions - Estate Planning...more

Insight on Estate Planning - February/March 2012

by Adler Pollock & Sheehan P.C. on 2/1/2012

In This Issue: - Does your trust need a protector? - Privacy, please! Keep family matters out of the public eye by avoiding probate - Consider a “stretch” to maximize and preserve IRA benefits - Estate Planning...more

End of the Year Legal Checklist

by Lawyers.com on 12/21/2011

Presents purchased? Check. Vacation time scheduled? Done. Holiday cards mailed? Yep. End-of-the-year legal checklist complete? Ye—wait a sec! What? If you truly want to start 2012 off on the right foot, there are a few...more

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Wills, Trusts, & Estate Planning › Insurance › Finance & Banking