Wills, Trusts, & Estate Planning Insurance Tax

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The Waters of March -The Benefits of Owning Life Insurance within a Cascading Charitable Lead Annuity Trusts (CLATs)

...I recall hearing Bossa Nova as a ten year old at my neighbor’s house in the Panama Canal Zone – Sergio Mendes and Brazil 66. The Waters of March is one of many great songs written by Antonio Carlos Jobim and sung by Elis...more

Bermuda: Taking Charge of the Future - A review of recent legislative changes relating to Trusts and Life Insurance Contracts

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 Estate Planner" – September/October 2014

In this issue: - The True Cost Of Giving – Charitable Donations In A No-Estate-Tax Environment - Could An Exchange Help Cover LTC Insurance Costs? - Family Meetings Help Ensure Estate Planning...more

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

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

"The Estate Planner" – July/August 2014

In this issue: - Net Gain For Taxpayers – Tax Court Approves Net Gift Strategy - Estate Planning For The Young And Affluent – How To Hedge Your Bets - Wealth Preserver – Use An ILIT To Shield Life...more

Is a quiet (silent) trust illusory?

Is a quiet or silent trust illusory? The question is intentionally ambiguous. Is the question whether the trust itself is illusory, or just its quietness? A quiet or silent trust has been defined as “an irrevocable trust...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

Tax-Qualified Retirement Plans: Amendments and Other Year-End Action Items - 11/21/2013

Plan sponsors should consider whether they need to make certain plan amendments or provide certain plan notices prior to the end of the year. The end of the year marks the deadline by which sponsors of qualified...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

The Power of Insurance Trusts to Maintain Family Business Assets and Sanity

Life insurance and irrevocable trusts are great tools to ease family business succession issues and mitigate exposure to shareholder oppression and disputes. Irrevocable life insurance trusts (ILIT), in particular, play an...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

Insight on Estate Planning - April/May 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

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 –...

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

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

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?

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...

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

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

IRS Releases Updated Employee Plan Correction Procedures

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

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

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