News & Analysis as of

UBTI Individual Retirement Account (IRA)

ArentFox Schiff

Self-Directed IRAs and the Prohibited Transaction Rules – Part 1

ArentFox Schiff on

Part 1: Permitted Investments and Compliance - The self-directed individual retirement account (IRA) is an increasingly popular option for an IRA account owner, especially those owners who have significant net worth and...more

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

Malta Vigor! The Partially Deductible Malta Pension Plan

Over the course of time I have ranted and raved about my love of Afro-Cuban aka Salsa. It wasn’t my dancing ability which attracted me to Latin music. For  the record, I am not a good dancer. Not even in my own mind. Maybe it...more

Eversheds Sutherland (US) LLP

Employee benefit arrangements potentially affected by revised UBIT calculations

In Notice 2018-67, released on August 21, 2018, the Internal Revenue Service (IRS) sought comments and provided interim guidance on changes in the calculation of unrelated business income tax (UBIT) enacted in the Tax Cuts...more

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

Malta Monopoly - Using Malta Pension Plans as An Alternative to the Traditional and Roth IRAs for Investing in Real Estate

Over the years I have seen a number of articles regarding investment in real estate by trustees of traditional and Roth IRAs. On the surface, investment is real estate, a long term investment, makes a lot of sense within a...more

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

My Big Fat Maltese Pension Plan - Finding Opportunities Above and Beyond the Roth IRA

One of the emerging planning strategies that is generally unknown and under-appreciated is the Malta Pension Plan (MPP). From the perspective of a U.S. taxpayer, the MPP should be viewed as an alternative that in many...more

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

If It’s Monday, It Must Be Malta! The Benefits of Malta Pension Schemes for U.S. Taxpayers

Since the passage of the Tax Cuts and Jobs Act (TCJA) on December 22, 2017, interest in the use of qualified retirement plans has increased. However, qualified retirement plans are not without their limitations and...more

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

Split-dollar Life Insurance – A Tax-Leveraged Derivative for Hedge Fund Managers

The Emergency Economic Stabilization Act of 2008 ended the not so discrete secret of hedge fund managers, the deferred compensation arrangement with their offshore funds or as the New York Times described, “an unlimited Super...more

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

My Broker at E.F. Hutton Says..........? -- Using Private Placement Variable Deferred Annuities (PPVA) to Invest in Real Estate...

Overview - American taxpayers have approximately $4.7 trillion invested in IRAs as of 2011. Only 2 percent of these assets or $94 billion are invested in self-directed IRAs. This is a surprising result when you...more

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