Tax Planning

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Annual Estate Planning Newsletter: Part Three

Action Item: This is the third installment of our Annual Estate Planning Letter, and covers some topics of interest not discussed in our previous installments. We urge you to review this installment to ensure that your 2016...more

Annual Estate Planning Newsletter: Part Two

Action Item: This is the second installment of our Annual Estate Planning Newsletter, and focuses on specific gift and generation-skipping transfer ("GST") tax matters. We urge you to review this installment to ensure that...more

What is a Section 83(b) election and why is it helpful to entrepreneurs?

Start-up founders, executives and other employees should understand the role that Internal Revenue Code Section 83 plays in effective tax planning when certain equity incentive grants are given in exchange for services....more

Tax Exclusions for Sale of Stock Issued by Qualified Small Business Corporations Becomes Permanent — At Least Temporarily

Over the past several years, Congress has sought to incentivize investment in small businesses by allowing taxpayers to exclude gains in certain small business stock sales. Gradually, Congress continued to increase these...more

New Partnership Audit Procedures May Dramatically Affect the Assessment and Collection of Taxes Relating to Partnership Activities

The Bipartisan Budget Act of 2015 (the “BBA”), which was signed into law in November 2015, includes sweeping changes to the rules governing federal tax audits of entities treated as partnerships for US federal income tax...more

Tax State Aid: The European Commission concludes Belgian ‘excess profit’ rulings illegal

On January 11 2016, the European Commission (the Commission) again used Tax State Aid arguments to combat tax planning by multinationals when it announced its final decision in the formal state aid investigation into the...more

Tax Update (Australia): Prospecting for Tax Deductions - The ATO Consolidates and Clarifies Its Views About When Exploration and...

The Commissioner of Taxation has released TR 2015/D4 - Income Tax: deductions for mining and petroleum exploration expenditure (Draft Ruling). The Draft Ruling will replace TR 98/23 - Income Tax: Mining exploration and...more

Somewhere Over the Rainbow

The Use of Private Placement Group Variable Deferred Annuities in Generation Skipping Trusts - Over the last several decades, trust and estate lawyers have placed great emphasis on proper planning regarding the proper...more

U.S. Pre-Immigration Tax Planning

The U.S. Pre-Immigration Tax Planning brochure provides information on the U.S. Tax Code, income tax, estate and gift tax, and pre-immigration considerations, in addition to real-world examples. There are no adverse...more

Tax and Estate Planning Newsletter - Winter 2015

Dear Clients and Colleagues: The holiday season brings thoughts of the New Year, with reflections on recent changes and resolutions for the future. During this season of reflection and planning, consider the effect of...more

The Game Has Changed: Congress Enacts Changes to IRS Partnership Audit Rules That Could Force Partnerships to Pay Tax - Tax Update...

The Bipartisan Budget Act will allow the IRS to collect taxes associated with audit adjustments at the partnership level, rather than passing adjustments through to the individual partners, effectively imposing entity-level...more

Change in the UK Treatment of Dual-Resident Companies May Affect U.S. Tax Planning

On November 30, 2015, the UK tax authorities at HM Revenue and Customs (HMRC) reached an agreement with Jersey about the interpretation of the company residence tie-breaker provision of the Jersey-UK income tax treaty. After...more

2015 Year-End Estate Planning Advisory

In 2015, 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

Can Correction of a Scrivener’s Error Retroactively Fix a Tax Problem with a Trust?

Yes, in a recently released Private Letter Ruling in regard to an irrevocable trust. There were actually two problems with the trust. First, the settlors retained powers to change the beneficial interests of the trust,...more

Retiring Abroad: The Lure of the Exotic, the Chore of U.S. Tax Compliance

For anyone who has watched the movie “The Best Exotic Marigold Hotel,” the idea of retiring overseas may be tempting. Glamorous locales exist around the world with warm sands, fragrant breezes and stunning sunsets where...more

Trusts, Estates, Exemptions and Taxes

It may be hard to believe that in 2001, the estate and gift tax exemption, also known as the unified credit, was a mere $675K. In 2016 that credit is anticipated to go up to $5.45M for single filers; potentially $10.9M...more

The Halloween Edition: Frights of Publicity and Celebrity Ghosts

It is an undisputed fact that the 90’s were the best. The deadcade gave us some of the best television (Buffy the Vampire Slayer), movies (Clueless), fashion (flannel), and music (Backstreet Boys). Everything created since...more

How to Avoid Needlessly Exposing a Client's Assets to Creditors in an Estate Plan or Trust

Estate planners often recommend that their clients hold title in community property or in a trust in which the real property interests are held as community property. They do this primarily to give the client the benefit of...more

Changing income tax rates in Alberta: What you need to know

Both the provincial government and the incoming federal government have raised, or have pledged to raise, income tax rates for high income earning individuals. Both have also pledged to make certain changes to corporate tax...more

New IRS Regulations for Mixed-Use Projects Financed With Tax-Exempt Bonds Have Practical Importance

On October 27, 2015 the U.S. Treasury Department and Internal Revenue Service published final regulations concerning the treatment of “mixed-use” projects financed with tax-exempt bonds. These new regulations have significant...more

Tax Evasion Vs. Tax Planning/Avoidance: Knowing The Difference Is Important

Last time, we began speaking about recent recommendations made by an international organization regarding tax avoidance which will reportedly make it harder for businesses to take advantage of tax law. As we noted, the...more

OECD Releases Final BEPS Recommendations – Now What?

On Oct. 5, 2015, the Organization for Economic Cooperation and Development (OECD) released a set of final reports on its 15 point action plan to address Base Erosion and Profit Shifting (BEPS). In an accompanying explanatory...more

Wealth Management Update - October 2015

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

Basic Tax Issues in Mergers and Acquisitions

Mergers and acquisitions ("M&A") are complex, multilayered transactions with multiple moving parts and a healthy dose of negotiation. There are, however, common tax implications at play in most transactions of which...more

Is It Time To Revisit One's Estate Plan?

It can be hard enough to realize the value of an estate plan. Those who realize such value can still fall into the trap of believing that such a plan is a "one and done" proposition, a set of documents that only needs to be...more

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