Tax Planning

News & Analysis as of

McDermott International Legal Highlights November 2016

The New World of Global Tax Planning: a Checklist for Success - As all multinationals (MNEs) are discovering, domestic implementation of the recommendations set out in the base erosion and profit shifting (BEPS) final...more

Trump and the Death Tax

Donald Trump’s tax plan calls for elimination of the “death tax,” which refers to the federal estate and generation-skipping transfer (“GST”) taxes, and may include the federal gift tax. His plan also calls for imposition of...more

Tax Planning for High-Net-Worth Individuals under a Trump Presidency

Tax reform is one of the central components of Donald Trump’s platform, and in many respects, his goals for tax reform are aligned with those described in the Tax Reform Task Force report issued by the House Republicans last...more

Tax Planning After Presidential Election

The recent presidential election cast a shadow of uncertainty over estate tax planning. President-elect Donald Trump’s platform includes a repeal of the federal estate tax and other proposals regarding our tax code. With...more

Foreign Entrepreneurs Series: Part 3 – U.S. Tax Considerations and Planning

This is the third part of our foreign entrepreneurs series. Previously, we discussed the visa options available to foreign entrepreneurs and the importance of making immigration analysis a first-step in the startup process. ...more

[Webinar] Business Planning in Light of Proposed Regulations under Code § 2704 - October 27th, 12:00p.m. CT

In this webinar, Steve Gorin, the author of his quarterly newsletter, will discuss the proposed regulations under IRC § 2704 that would increase the valuation of business entities in many cases. Attendees will learn when the...more

Transferee Liability: The [Unlikely] Situation that your Nonprofit Receives a Charitable Gift with Expensive Tax Strings Attached

The case of Salus Mundi Foundation et al v. Commissioner - On August 15, 2016, the Tax Court decided in Salus Mundi Foundation et al v. Commissioner, T.C. Memo. 2016-154, that two foundations were liable as transferees...more

Projected Inflation-Adjusted Estate, Gift and GST Tax Exclusion Amounts for 2017 Now Available

Based on the Consumer Price Index for the 12-month period ending August 31, 2016, Thompson Reuters Checkpoint has released their projected inflation-adjusted Estate, Gift, GST tax, and other exclusion amounts for 2017, as...more

IRS Proposes Regulations That Will Eliminate Most Valuation Discounts on Family-Owned Entities

On August 2, 2016, the IRS issued proposed regulations that would eliminate or limit the use of certain valuation discounts regularly applied when valuing interests in family-owned entities for gift and estate tax...more

Pre-immigration and Non-U.S. Resident Planning

Foreign individuals who intend to permanently reside in the U.S., or do not intend to reside in the U.S. but intend to own U.S. property, need considerable legal and tax planning. The definition of “U.S. property” for...more

Focus on Tax Strategies & Developments - August 2016

Brexit: The Consequences for International Tax Planning - Just over a month has now passed since the referendum in which the United Kingdom voted narrowly to leave the European Union: an event which some have...more

Family Limited Partnerships: Estate Tax Benefits and More

Family limited partnerships have long been a valuable tool of the estate planner. Although historically recognized as providing estate tax planning benefits through the discounted value of assets, these limited partnerships...more

Conserve Your Land, Preserve Your Estate: The Conservation Easement as a Land Use, Tax & Estate Planning Tool

We have all been told at one point or another that we simply “can’t have it all.” But for owners of recreational or agricultural land who desire to preserve the land, pass it down to their descendants as a legacy property,...more

Foreign Bank Account Reporting and Employment Tax Enforcement: Ronn Owens interviews Steve Moskowitz [Audio]

Ronn Owens interviewed Steve Moskowitz on June 28 and they discuss IRS priorities, including Foreign Bank Account Reporting and Employment Tax Enforcement. Steve and Ronn further discuss the history of individual tax rates...more

Beware: Your Estate Plan May Contain an Unnecessary Bypass Trust

A once-popular estate planning tool included in many Last Wills and Revocable Trusts may now cost families more in taxes than it saves. Changes in the federal estate tax have made the "bypass trust" which was often included...more

Avoiding Pitfalls When Forced to Start Breaking Your Retirement Piggy Bank

The oldest of the 75 million baby boomers have begun turning 70 in 2016. Becoming a septuagenarian is a milestone in itself, but it also means that soon the IRS will likely be expecting you to start cashing out your...more

Estate Tax Changes Past, Present and Future

I. INTRODUCTION - This outline is a selective and evolving review of the history of the modern federal estate tax. It originated during the attempts to repeal the estate tax in President Clinton’s second term and...more

Section 385 Proposed Regulations

On April 4, 2016, Treasury and the IRS proposed sweeping regulations under § 385 of the Code. Issued the same day as the anti-inversion temporary regulations, the proposed § 385 rules would go much farther than merely...more

IRS Issues Proposed Regulations That Would Recast Certain Debt Instruments as Equity

On April 4, 2016, the IRS and U.S. Treasury Department, in connection with a package of anti-inversion regulations prompted by news of the recent spate of corporate inversions (particularly the $160 billion Pfizer-Allergan...more

The Atomic Leg Drop of Charitable Tax Planning

Using Charitable Tax Planning to Help Hulk Hogan and Other Settlement Recipients Mitigate Tax Submission Holds in Settlements - Overview - I grew up in the Panama Canal Zone watching “ Lucha Libre” (Wrestling) on...more

Be Organized to Preserve Your Charitable Deductions for Property Donations

3 Things to Remember About Documenting Charitable Gifts of Property, Securities and Art. Last month in this blog, we described five ways to be diligent about documenting charitable gifts of cash or out-of-pocket expenses...more

Proposed Regulations Would Fundamentally Change Treatment of Intra-Group Debt Transactions

On April 4, 2016, the U.S. Department of the Treasury and Internal Revenue Service (IRS) issued two sets of regulations, temporary regulations addressing “inversion” transactions and proposed regulations regarding the...more

The Use Of Trusts In Business Succession Planning

The transition of a family owned or closely-held business is an important event for estate planning clients. Historically, the use of trusts has played an important role in business succession planning. Recent changes to the...more

The Charitable Split Annuity – A Little Bit Country and a Little Bit Rock and Roll

I have written several articles discussing the powerful tax benefits of pooled income funds in the current low interest environment. I have also written on the tax benefits of charitable lead annuity trusts (CLAT). The pooled...more

Estate Planning and Administration – Be Prepared for the Year That Follows the Death of a Loved One

The loss of a loved one is a traumatic event and it can be among the most challenging of times to make important financial decisions. Proactive planning with an attorney and financial planner can significantly lessen the...more

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