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
President Biden recently signed into law the Secure 2.0 Act of 2022. The Act contains, in part, an expansion of the rules for qualified charitable distributions. A qualified charitable distribution (“QCD”) is a direct...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
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
Delaware Clarifies “Pro-Sandbagging” Stance by Mark Tarallo and Mary Moran In almost every M&A transaction, the parties spend some time discussing (if not heavily negotiating) the right of the buyer to bring claims against...more
On January 3, 2009, an alternative currency was born, known as Bitcoin—a cryptocurrency or virtual currency secured through digital blockchain technology, allowing electronic monetary transactions from person to person...more
By using a Charitable Unitrust Remainder Trust (CRUT), philanthropic minded donors can gift to a charitable cause while maintaining a lifetime benefit. A CRUT is an irrevocable agreement that will provide an income stream to...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
Last year brought with it several unexpected challenges due to the COVID-19 pandemic, including economic, social, and financial hardships that have left many in a position of extraordinary need. ...more
The Setting Every Community Up for Retirement Enhancement (SECURE) Act is the biggest retirement planning law in decades. However, when all is said and done, the new law may have just as significant an impact on estate...more
According to statistics 40-50 percent of all marriages end in divorce. To add insult to injury, tax reform eliminated the deductibility of alimony payments for divorce and separation agreements that are finalized or amended...more
Overview - The first installment of this article focused on the bad news regarding limitations to Stretch IRAs as a result of the SECURE Act. This segment focuses on some alternative planning uses of the Pooled Income Fund...more
The Setting Every Community Up for Retirement Enhancement Act (the SECURE Act) was signed into U.S. law on December 20, 2019. The SECURE Act makes significant changes to the administration of IRAs and other tax-deferred...more
On December 20, 2019, the Setting Every Community Up for Retirement Enhancement (SECURE) Act (the“Act”) was signed into law drastically altering the administration of certain retirement plans such as IRAs and 401Ks. Although...more
Many people like the idea of leaving bequests to favorite charities in their wills. But instead of leaving money to a charity in your will, you can put that money into a charitable remainder trust and collect income while you...more
As predicted, the 2017 Tax Act appears to have impacted the state of charitable giving in the United States. The 2019 Giving USA report released June 18, 2019, indicated that giving by individuals declined by 3.4 percent...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
I have personally observed in my professional travels that many taxpayers are reluctant charitable donors. However, we you remind a business owner that they only have three choices when it comes to taxes (1) Pay yourself;...more