On March 25, 2024, the IRS issued proposed regulations (REG-108761-22) which, if finalized, would identify certain CRATs as listed transactions. For those unaware of the listed transaction rules, such a designation would...more
El 10 de abril de 2024, como parte de su campaña de la Docena Sucia (“Dirty Dozen”) para 2024, el IRS emitió una advertencia a individuos de alto patrimonio con respecto a tres trampas fiscales diseñadas para ellos por...more
On 4/10/24, as part of its Dirty Dozen Campaign for 2024, the IRS issued a warning to High Net Worth Individuals regarding three tax traps designed for them by dishonest promoters and shady tax practitioners. High Net Worth...more
On April 5, 2023, the IRS wrapped up its Dirty Dozen 2023 list – earlier than the release of the Dirty Dozen 2022 list which was published on June 10, 2022. According to the IRS, the Dirty Dozen represents the worst of the...more
Every year, the IRS compiles a list of common scams that taxpayers may encounter – its so-called “Dirty Dozen.” Today, the Service wrapped up the annual Dirty Dozen list of tax scams for 2023 with a reminder for taxpayers,...more
By most accounts, 2022 has been a tumultuous year from a planning perspective: the uncertainty of the midterm elections, stock market volatility, rising interest rates and the highest level of inflation in recent history have...more
As interest rates continue to climb, taxpayers will begin to see a greater benefit from strategies that leverage higher interest rates to reduce the actuarial value of a taxable gift. The higher the rate, the more favorable...more
According to the IRS, the Dirty Dozen represents the worst of the worst tax scams. The Dirty Dozen is a list that is compiled annually by the IRS in order to alert taxpayers, tax professionals and financial institutions of...more
Earlier this year the stock market entered bear market territory. This happens when the market declines more than 20% or more from its most recent high. The market decline has been attributed to several factors including...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 31, 2022 – June 3, 2022... May 31, 2022: The IRS issued a press release, reminding...more
In the past year, the global market capitalization of cryptocurrency has grown exponentially, reaching a high of $2.56 trillion on May 11, 2021. Coinbase, the largest cryptocurrency exchange, has more than 68 million verified...more
I have been posting my articles on JD Supra since August 2012. I am grateful to JD Supra for helping me to spread the tax gospel of Nowotny to readers. As of today, my articles have had 523,887 views. If my Mom and Dad (of...more
Part 1 of our Article addressed why a charitably-inclined client should make a gift to charity in the year of business sale. Having completed the analysis of when it is best to make a gift, some clients may hesitate to...more
On January 18, 2019, the Internal Revenue Service (IRS) issued final regulations implementing the new pass-through income deduction for qualified business income (QBI) received from pass-through entities (such as sole...more
The addition of IRC Sec 457A effectively ended the ability of investment managers to defer the tax recognition of the carried interest in the investment manager’s offshore fund. Under IRC Sec 457A, hedge fund managers must...more
There are many charitable giving options that are available to fit a donor’s specific goals. You do not have to be Bill Gates or Warren Buffett to make a difference in the world now and after you are gone. Most of our...more
Have you heard? More people can now use charitable remainder annuity trusts thanks to new IRS guidance in the form of Revenue Procedure 2016-42, issued recently....more
While most of us think of charitable giving around the holidays (or around tax time!), for many it is prudent to plan your giving to receive all of the benefits that are available to you. Planned giving comes in many forms...more
October Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The October § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more
Most people make the bulk of their charitable contributions during the year-end holiday season. This post summarizes some of the charitable giving ideas and opportunities, as well as some planning reminders, that donors may...more