News & Analysis as of

High Net Worth Family Tax Report, Vol. 9, No. 2

What You Need to Know About Corporate Inversions - It seems like every day brings news of another possible corporate inversion transaction. The news reports usually describe these transactions as another United States...more

Limitation on IRA Rollovers: Once Per Year Only

The Internal Revenue Service (“IRS”) has narrowed the rules relating to Individual Retirement Account (“IRA”) rollovers by withdrawing longstanding proposed rules to reflect a recent U.S. Tax Court ruling in Bobrow v....more

IRS Takes New Position on IRA 60-Day Rollover Rule: Bobrow v. Commissioner, T.C. Memo 2014-21

In light of its recent Tax Court victory in Bobrow v. Commissioner, the IRS is taking a tougher stance on a taxpayer's ability to make more than one tax-free/penalty-free IRA rollover per year. This change in policy will take...more

New IRA Rollover Interpretation Has Implications For Banks

In a new interpretation with implications for banks, the Internal Revenue Service (IRS) announced its intent to change course and limit rollovers from an Individual Retirement Account (IRA) to one rollover per year per...more

IRS Issues Notice on Expanded In-Plan Roth Conversion Option

Guidance confirms that plan sponsors have flexibility in designing and implementing a feature that allows participants to convert vested pre-tax balances to after-tax Roth balances....more

DOMA’S Demise Has Broad Impact on U.S. Benefit Plans: Prepare for new claims and practices

When you heard about the invalidation of the part of the Defense of Marriage Act (DOMA) that defined marriage as between a man and a woman by the United States Supreme Court, you probably thought: “Now my plan is going to...more

American Taxpayer Relief Act Affects Mass Transit Benefits and Other Employee Benefits

On January 2, 2013, President Obama signed the American Taxpayer Relief Act of 2012 ("ATRA") into law. ATRA, adopted as an alternative to stepping over the "fiscal cliff," preserves most of the Bush-era tax cuts and...more

Rates of Change: The Effect of the American Taxpayer Relief Act of 2012 on Individual and Fiduciary Income Taxes

For all the public discussion in 2012 of the need for a significant reformation and restructuring of the Internal Revenue Code, the income tax provisions of the American Taxpayer Relief Act of 2012 (the 2012 Act) are at their...more

IRS Announces Deadline to Make 2012 Charitable/IRA Rollovers

On January 16, 2013, the IRS issued a notice (IR-2013-6) advising that certain IRA owners have a limited time to make tax-free transfers to eligible charities and have them count for 2012. IRA owners age 70½ or older have...more

American Taxpayer Relief Act Of 2012 Impact On Charitable Giving And Exempt Organizations

The American Taxpayer Relief Act of 2012 (the “Act”) was passed by the United States Congress on January 1, 2013 and signed into law by President Obama on January 2, 2013. The following provisions of the Act should be of...more

Significant Estate Planning Developments in 2013

The American Taxpayer Relief Act of 2012 (Act) was enacted on January 2, 2013....more

Congress Avoids the Fiscal ‘Cliff’—Now What?

The new federal tax bill establishes permanent income, estate, gift and generation-skipping transfer tax provisions that present additional planning opportunities for 2013 and beyond. ...more

New Tax Act's Impact on Planning for Charitable Donations

New Year's Day brought new tax legislation passed by Congress, called the American Taxpayer Relief Act of 2012 (the "Act"), which President Obama has signed into law. The Act has made some important changes to the tax law...more

Charitable Giving Under the New Tax Law: A Unique (But Brief) Opportunity for IRA Rollovers and Other Highlights

The American Taxpayer Relief Act of 2012 enacted in Washington last week creates a unique opportunity for charitable giving. Individuals with IRAs who have attained age 70½ may make a tax-free rollover to charity of up to...more

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