Wills, Trusts, & Estate Planning, Insurance, Tax Law

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

Insight on Estate Planning - April/May 2013

by E. Hans Lundsten, Joseph Marion, III, David Riedel, Christina Scola | Adler Pollock & Sheehan P.C. on 4/16/2013

In This Issue: - How to fund long-term care insurance with a tax-free exchange - Should a CRT be part of your estate plan? - The key to an effective trust is education - Estate Planning Pitfall:...more

Insight on Estate Planning - April/May 2013: How to fund long-term care insurance with a tax-free exchange

by Adler Pollock & Sheehan P.C. on 3/28/2013

Long-term care (LTC) insurance is a major expense, especially for someone who purchases it at or after retirement age. One potential source for funding LTC insurance premiums is a total or partial tax-free exchange of an...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

IRS and US Department of Labor Continue to Expand, Encourage and Simplify Correction Programs in 2013 Updates to EPCRS and DFVCP

by Gregory Brown, Christopher K. Buch, Russell E. Greenblatt, Gary Howell, Ann Kim, Daniel B. Lange, William Mattingly | Katten Muchin Rosenman LLP on 3/1/2013

Plan sponsors know that errors and failures in administering a retirement plan happen. All too often, changes in administrators, service providers and other staff uncover errors and compliance problems that should be...more

Insight on Estate Planning - February/March 2013

by Adler Pollock & Sheehan P.C. on 2/26/2013

In This Issue: - Fiscal cliff deal brings some certainty to estate planning - Strong governance enhances a family business’s value - Should you donate life insurance to charity? - Estate Planning Pitfall -...more

Insight on Estate Planning - February/March 2013: Should you donate life insurance to charity?

by Adler Pollock & Sheehan P.C. on 2/22/2013

Donating life insurance to a favorite charity is an excellent opportunity to make a larger donation than may otherwise be affordable. This article shows why this is so and discusses the most tax-effective way to donate life...more

Union Friendly - Using Collectively Bargained Benefit Plans to Maximize Employee Benefit Plan Contributions for Closely Held...

by Gerald Nowotny on 2/18/2013

Overview - Part I and Part II have focused on the tax planning possibilities of small business owners and owners of professional corporations utilizing an exemption for collectively bargained plans. This exemption allows...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

IRS Releases Updated Employee Plan Correction Procedures

by Lori Atkin, Dennis R. Bonessa, Dodi Walker Gross, John D. Martini, Allison Warden Sizemore | Reed Smith on 1/9/2013

On December 31, 2012, the Internal Revenue Service (the “IRS”) released Revenue Procedure 2013-12, which contains long-awaited updates to the Employee Plans Compliance Resolution System (“EPCRS”), previously set forth in...more

No Nukes! - Using Tax-Advantaged Investments to Enhance Investment Returns in Nuclear Decommissioning Trusts

by Gerald Nowotny on 12/4/2012

A.Overview - This executive summary is intended to outline the use of private placement insurance contracts as a funding vehicle for nuclear decommissioning trusts (NDT). As of the end of 28 investor-owned and 28...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

Policy Loans Can Bite You

by Charles (Chuck) Rubin on 11/9/2012

Life insurance policies can be great vehicles for income tax deferral. Part of this arises from the fact that earnings growth that occurs inside the policy is not subject to current income tax (and may never be taxed if the...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

Home

Legal News

Find a Lawyer

Browse Subjects

Subscribe

Pro Services

For Reporters

Wills, Trusts, & Estate Planning › Insurance › Tax Law