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Tax Deferral Income Taxes

Mayer Brown

ESOP Update: Installment Sales Rules Save ESOP Footfall in Berman v. Comm’r

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Berman v. Comm’r,  released on July 16, 2024, is a great example of making lemonade when life hands you a lemon. Although the taxpayers lost the federal income tax deferral of a stock sale to an employee stock ownership plan...more

Fisher Phillips

2024 Employee Benefit Limits Plus 6 Best Practices for Employers

Fisher Phillips on

Get Ready For The New Year Ahead - Employees can contribute more pre-tax dollars next year to their retirement savings accounts, including 401(k) and 403(b) plans, according to an IRS announcement made on November 1. Your...more

Gray Reed

The IRS is Attacking Abusive Trust Arrangements

Gray Reed on

Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more

Rivkin Radler LLP

Enough Already – Eliminate Downward Attribution and Accidental CFCs

Rivkin Radler LLP on

It’s Complicated- The Code includes a number of complex rules that are aimed at those overseas business and investment activities of U.S. taxpayers that Congress has determined may result in the improper deferral or...more

Perkins Coie

Washington Capital Gains Tax: More Questions, Tentative Answers

Perkins Coie on

Nearly two years after being enacted by the state legislature, and one year after being struck down by a lower court, the Washington state capital gains tax has been reinstated as constitutional, and the first returns and...more

McDermott Will & Emery

Weekly IRS Roundup December 5 – December 9, 2022

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 5, 2022 – December 9, 2022...more

Gerald Nowotny - Law Office of Gerald R....

(A)ESOP's Fables - The Income and Estate Tax-Free ESOP

ESOPs are a great tool for the business owner and employees. The planning technique complimenting the ESOP dramatically enhance the benefits for the Seller making the Seller more willing to enter into the ESOP arrangement....more

Rivkin Radler LLP

Selling Your Business? Take the Money But Defer the Tax?

Rivkin Radler LLP on

Sale of the Business- Imagine Client has just received an attractive, all cash offer for the sale of their business; there is no financing contingency. The buyer has proposed a cash-free and debt-free deal....more

Oberheiden P.C.

Can You Defer Taxes on Your Crypto Investments? Ten Tips for What You Need to Know

Oberheiden P.C. on

U.S. taxpayers have an obligation to both report their cryptocurrency transactions to the IRS and pay taxes on it. Individuals who hold on to their cryptocurrencies as an investment are subject to short- and long-term capital...more

McDermott Will & Emery

Weekly IRS Roundup December 13 – December 17, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 13, 2021 – December 17, 2021. December 13, 2021: The IRS published a memorandum...more

Rivkin Radler LLP

The Tax-Deferred Rollover – Some Considerations

Rivkin Radler LLP on

“I have wondered at times what the Ten Commandments would have looked like if Moses had run them through the U.S. Congress.” – Pres. Ronald Regan- That line probably describes the exasperation with which many Americans...more

McDermott Will & Emery

The 90 Percent Test

McDermott Will & Emery on

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

Levenfeld Pearlstein, LLC

Better Act Before The Build Back Better Act

It is said that two things are certain in life: death and taxes. True, but incomplete. What is missing from this short list is a third inevitable occurrence – tax law changes. We now have a new and pressing series of proposed...more

Fenwick & West LLP

Section 987 Practice Unit Reflects a Permissive Attitude Towards Different Methods of Branch Currency Translation

Fenwick & West LLP on

A few weeks ago, the IRS released a new “practice unit” providing training for its examiners on translation of foreign currency gains and losses of branches (so-called qualified business units, or QBU) under §987....more

Gerald Nowotny - Law Office of Gerald R....

TAKE A CHANCE ON ME! Tax Planning During the Biden Administration

Take a chance on me series discusses niche strategies to achieve tax reduction and deferral. #taxstrategy #ppli #pooledincomefund #maltapensionplan #estateplanning ...more

Gerald Nowotny - Law Office of Gerald R....

TAKE A CHANCE ON ME! Tax Planning During the Biden Administration

Nowotny On Death and Taxes episode ,Take A Chance On Me! focuses on innovative strategies for tax reduction and deferral. Not only are we good at creating the ideas but we're good at implementing the ideas as well. #ppli...more

Cole Schotz

Starting An Active Business In An Opportunity Zone

Cole Schotz on

This short article outlines the requirements for starting an active business in a qualified opportunity zone (“QOZ”). The US tax legislation that created QOZs was enacted in early 2018, and is intended to encourage...more

Rivkin Radler LLP

Cash In Hand, Tax Deferral, Monetized Installment Sales: No, You Can’t Have It All

Rivkin Radler LLP on

Ask the owner of a closely held business to describe their most recently recurring nightmare and you are likely to get an earful regarding the prospect of an increased federal income tax on their profits, an increased federal...more

Stinson LLP

IRS Issues Final Carried Interest Regulations

Stinson LLP on

The tax treatment of carried interests was changed with the enactment of Section 1061 of the Internal Revenue Code as part of the 2017 Tax Cuts and Jobs Act. After issuing proposed regulations last summer, the Internal...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Final Regulations on Timing of Income Recognition Provide Much-Needed Clarity, But Leave Some Questions Unanswered

On December 21, 2020, the Treasury Department (Treasury) and the IRS released final regulations (Regulations) under Section 451 for determining the taxable year in which an amount must be reported as gross income on the...more

Lewitt Hackman

COVID-Related Tax Relief Act Summary

Lewitt Hackman on

Congress passed the $900 Billion COVID-Related Tax Relief Act of 2020 (“COVIDTRA” or “the Act”) as part of the Consolidated Appropriations Act of 2021, on December 21, 2020. As of this writing, President Donald J. Trump has...more

Gerald Nowotny - Law Office of Gerald R....

INTRODUCING MALTA SPLIT DOLLAR

Learn how to convert tax deferred dollars into tax-free dollars using Malta Split Dollar....more

Bowditch & Dewey

2020 End of Year Tax Planning for Businesses

Bowditch & Dewey on

As the 2020 year draws to a close, businesses should review the tax-related provisions adopted in the CARES Act and related IRS guidance with their tax advisers: EMPLOYER REFUNDABLE CREDIT AND PAYROLL TAX DEFERRAL: -...more

Foley & Lardner LLP

Speculation on the Content and Timing of Potential Tax Law Changes in 2021 and 2022

Foley & Lardner LLP on

The November 3 election may have dramatic impacts on the income and estate tax laws. These changes could become effective as early as January 1, 2021. Of course, a big uncertainty is the outcome of the election, and whether...more

Gerald Nowotny - Law Office of Gerald R....

THE WONDER YEARS WEBINAR

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

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