RETURN TO FOREVER - What Game Shall We Play Today?
INTRODUCING MALTA SPLIT DOLLAR
WHERE EAGLES DARE-INTRODUCING MALTA SPLIT DOLLAR
ISLA DEL ENCANTO - INTRODUCING BORICUA SPLIT DOLLAR
Isla del Encanto-Introducing Boricua Split Dollar
THE WONDER YEARS WEBINAR
HEAVEN CAN WAIT
THE WONDER YEARS WEBINAR - LOAN REGIME METHOD OF SPLIT DOLLAR LIFE INSURANCE
PRIVATE PLACEMENT LIFE INSURANCE WEBINAR
WHERE HAVE YOU GONE, CHIP HILTON?
THE WAY WE WERE
THE PAPER CHASE
THE SPLIT DOLLARMINATOR!
Mad Dogs and Panameños!
Tax Litigation: The Week of February 28, 2022, through March 4, 2022 - Shaddix v. Comm’r | TC Memo. 2022-11 | February 28, 2022 | Lauber, J. | Dkt No. 12683-20L - Estate of Kazmi v. Comm’r, T.C. Memo. 2022-13| March 1,...more
I Read the News Today- Much of today’s news is dominated by the future of the Administration’s broadly defined infrastructure plan. Discussions among “those in the know” inevitably turn into debates over the wisdom of...more
Loan Regime Method of Split Dollar Life Insurance - This webinar covers: What is Split Dollar? Loan Method versus Economic Benefit. Leverage Split Dollar Rollout. Planning examples using Split Dollar....more
Hedge Fund managers previously had an unprecedented ability to defer their carried interest in the offshore hedge funds that they manage. IRC Sec. 409A put an end to those deferrals and required hedge fund managers to...more
In this video Gerry, discusses how a business can use a commercial loan from a bank or a financial institution to help finance it's business obligation in the Loan Regime Split Dollar Method and deduct the interest on the...more
Nowotny on Death and Taxes, episode 17, THE SPLIT DOLLARMINATOR! Using Commercial Lending to “Juice” the Funding of Loan Method Split Dollar Arrangements How a business can use a commercial loan from a bank or a financial...more
This article focuses on how a business can use a commercial loan to help finance a business’ obligation in a Loan Regime Split Dollar Arrangement and deduct the interest payments for its tax purposes, without running afoul of...more
My father (of blessed memory), Willy Wolfgang Nowotny, died last November at the age of 85. He was born and raised in the Saxon region of East Germany on the Czech and Polish borders. I always figured his town was the German...more
On June 18, 2018, the Tax Court issued a memorandum denying a motion for partial summary judgment filed by the Estate of Richard Cahill (T.C. Memo 2018-84). It was the second time in two years that the Tax Court had addressed...more
Overview - In the last ten years, life insurance producers and their counsel have quietly transferred great fortunes with minimal gift and estate taxation using intergenerational split dollar life insurance programs....more
In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more
In August 2016, the national sports media provided details regarding the compensation package for Coach Jim Harbaugh at the University of Michigan. It comes as no surprise to anyone that Division I football and basketball...more
Recently I wrote an article on JD Supra called Split to Be Tied (May 4, 2016) regarding the Tax Court decision in Estate of Morrissette, (Estate of Clara M. Morrissette v. Commissioner, 146 T.C. No. 11 (April 13, 2016)). Once...more
June Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts The June § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs...more