Net Investment Income

News & Analysis as of

After the Love is Gone – Tax Planning Considerations for Private Equity and Venture Capital Fund Managers in a Post-Carried...

Overview - The issue of carried interest taxation as obscure an issue as it is, has gotten all kinds of attention in the media over the last several years. Most recently, the issue garnered national attention during...more

Implementing the Affordable Care Act: Countdown to 2014 - Tax Increases Under the Affordable Care Act.

Under the Affordable Care Act, a number of significant tax increases go into effect in 2013 and other tax provisions will be implemented during the next several years. Provisions starting in 2013 include: Additional...more

High Net Worth Family Tax Report, Vol. 8, No. 1 - January 2013

Table of Contents: Remember to file your gift tax return and other follow-up related to 2012 gifts; Review estate plans in light of $5 million exemption becoming permanent; Annual exclusion amount for gifts increased for...more

Fiscal Cliff Legislation Extends Tax Incentive to Invest in Small Businesses

As a result of the recent “fiscal cliff” legislation, otherwise known as the American Taxpayer Relief Act of 2012 (2012 Tax Act), many individual investors are expecting future tax increases, either in the form of higher...more

Non-Grantor Trusts – A Double-Edged Solution for Taxpayers Living in States with High Taxes

Overview - This article discusses the use of non-grantor trusts as an asset protection planning tool, while introducing the non-grantor trust as an income tax planning tool in order to reduce taxpayer’s exposure to state...more

Congress Extends the 100% Tax Exemption for Gain on Certain Qualified Small Business Stock, With Retroactive Effect, Through 2013

On January 2, 2013, President Obama signed into law the American Taxpayer Relief Act of 2012 (the “Act”). Among its provisions, the Act extends a tax benefit whereby capital gains from the sale or exchange of certain...more

Legal Alert: The 2012 Tax Litigation Year in Review: Important Events

The year 2012 was quite an interesting one for tax controversy. Whereas 2011 brought a win for the Treasury on deference issues in Mayo Foundation for Medical Ed. v. United States, 131 S. Ct. 704 (2011), 2012 was the year...more

Obamacare – Will the New Taxes Impact Me?

Political debate for the past two years has focused on the future of the Patient Protection and Affordable Care Act, more recently called “Obamacare,” and the taxes enacted by Congress to help pay for it. With the national...more

2013 Brings New Taxes to High Income Taxpayers

The Patient Protection and Affordable Care Act (sometimes called “Obamacare”) comes with two new taxes for higher income taxpayers beginning on January 1, 2013: (i) a 3.8 percent Medicare contribution tax on net investment...more

New 3.8% Tax on “Net Investment Income” – IRS Issues Proposed Regulations

The Internal Revenue Service has issued Proposed Regulations under Section 1411 of the Internal Revenue Code providing guidance on the 3.8% additional tax that will be imposed beginning January 1, 2013 on the “net investment...more

New 3.8% Medicare Tax on Investment and Unearned Income Beginning in 2013

Starting January 1, 2013, a new 3.8% Medicare tax will apply to the investment and “unearned income” of individuals, trusts and estates. The tax is intended to apply to income exempt from the regular FICA or self-employment...more

Estate Planning Update - September 2012: New Taxes Make Year-End Income Tax Planning More Important

It is not too early to start planning income tax steps to take before year-end. The Patient Protection and Affordable Care Act introduced two new taxes that will go into effect January 1, 2013. These are a 3.8 percent...more

Considerations For Tax Planning Opportunities Prior to December 31, 2012

This outline is not intended to be a comprehensive outline, but is intended to be a helpful resource summarizing the federal income tax and cited financial planning opportunities available before December 31, 2012 for...more

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