News & Analysis as of

High Net-Worth Tax Planning

Mayer Brown

Measure ULA Update: Reported Revenue, Applicability to Foreclosures and Legal Challenges

Mayer Brown on

In a February Legal Update, we analyzed the Taxpayer Protection and Government Accountability Act (the “Taxpayer Protection Act” or the “Act”), a statewide California ballot initiative that could potentially repeal the...more

Holland & Knight LLP

Maximize Your Legacy: Take Advantage of the High Estate and Gift Tax Exemption Sunset

Holland & Knight LLP on

As part of the Tax Cuts and Jobs Act (TCJA), the estate and gift tax exemption was doubled for tax years 2018-2025. In 2018, the exemption doubled from $5.49 million in 2017 to $11.18 million in 2018, and that amount has been...more

Venable LLP

Political Giving: A Primer for High-Net-Worth Individuals and Family Offices

Venable LLP on

For many years, supporters of a candidate or a cause simply wrote a check and asked friends and colleagues to do the same. But the opportunities to influence elections and public policy have evolved significantly, allowing...more

Nutter McClennen & Fish LLP

Legacy Matters (Spring 2024)

Welcome to the spring edition of Legacy Matters, Nutter’s private wealth and nonprofit newsletter focusing on estate planning and philanthropy topics. In this issue, we analyze charitable deductions and required recordkeeping...more

Falcon Rappaport & Berkman LLP

IRS Announces Audits of Business Jet Usage as Part of Larger Effort to Target High-Income Taxpayers

On February 21, 2024, the IRS announced plans to begin audits on aircraft that may be used for both business and personal purposes. This push is a part of the IRS’s broader focus on improving tax compliance in high-income...more

Nutter McClennen & Fish LLP

Legacy Matters (Fall 2023)

Welcome to the first edition of Legacy Matters, Nutter’s private wealth and nonprofit newsletter focusing on estate planning and philanthropy topics. ...more

Gray Reed

The IRS is Hiring an Army to Audit Corporations, Partnerships, and High-Income Individuals

Gray Reed on

The IRS has been understaffed for many years, and this has led to a decline in the number of audits conducted.  The personnel shortage has also made it difficult to keep up with the growing complexity of the tax code and to...more

Greenberg Glusker LLP

Top Tax and Legal Considerations for Wealthy Families Going Global

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In recent years, we have seen high net-worth and ultra-high-net-worth families become, increasingly, “global citizens.” As families and their assets touch multiple jurisdictions, a myriad of issues become especially important...more

Gray Reed

Is Your Partnership Ready for IRS Audit Initiatives? Because the IRS is Coming!

Gray Reed on

On September 8, 2023 the IRS announced a sweeping effort to focus enforcement efforts on high-income individuals, partnerships, and corporations. On September 20, 2023 the IRS announced that it will establish a special...more

Allen Barron, Inc.

IRS Warns High Income US Taxpayers and Millionaire Non-Filers

Allen Barron, Inc. on

The IRS has recently issued an ominous notice (#IR-2023-126) in which the IRS warns high income US taxpayers and millionaire non-filers that the IRS is targeting them to conduct audits, identify and collect undeclared income...more

Polsinelli

Beware, the IRS is Coming: More IRS Audits to Focus on High-Net Worth Individuals and Passthrough Entities

Polsinelli on

After much anticipation, the IRS has finally announced a strategic operating plan to spend the nearly $80 billion in funds that it was allocated through the Inflation Reduction Act. Since this bill was signed, the new IRS...more

Cadwalader, Wickersham & Taft LLP

Potential Constitutional Challenge: Biden Budget Proposes Mark-to-Market for High-Net-Worth Individuals

In President Biden’s State of the Union address, he called on all Americans to pay their “fair share.” The Treasury Department’s General Explanations of the Administration’s Fiscal Year 2024 Revenue Proposals contains several...more

McDermott Will & Emery

[Event] Private Client Roundtable - March 15th, Boston, MA

McDermott Will & Emery on

Thaw out with McDermott’s Tax and Private Client teams during our first (of many) Boston Private Client Roundtables where attendees can reconnect with peers in the tax, private client and wealth advisory space in the city. We...more

Cadwalader, Wickersham & Taft LLP

The States Come Marching In: Investors Ignore State Wealth Taxes at Their Peril

As President Biden reminded taxpayers in his recent State of the Union address, the federal government continues to pursue new taxes on high-net-worth individuals. While such efforts have foundered in Congress, causing many...more

Morgan Lewis

Planning for the Massachusetts ‘Millionaires Tax’

Morgan Lewis on

The new Massachusetts “Millionaires Tax” imposes an additional 4% income tax on the portion of annual taxable income in excess of $1 million (indexed for inflation), starting in 2023. The new tax will affect high-income...more

Allen Matkins

Attention Property Owners: Los Angeles and Santa Monica Approve ‘Mansion Tax’ Ballot Measures, Increasing Transfer Taxes on Sales...

Allen Matkins on

Residents of Los Angeles have approved Measure ULA, a ballot measure widely known as the “Mansion Tax,” which increases transfer tax rates on real estate sales valued at $5 million or more. Prior to Measure ULA, real estate...more

Goulston & Storrs PC

Taxachusetts Redux? The New Massachusetts Millionaires Tax

Goulston & Storrs PC on

On November 8, 2022, Massachusetts voters elected to adopt Question 1, the so-called Fair Share Amendment or Massachusetts Millionaires Tax, through a ballot referendum. The referendum amends the Massachusetts state...more

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

Papa Has a Brand New Bag

The high-net-worth PPLI marketplace has started to resemble the retail VUL marketplace but with institutional pricing and investment options that are more sophisticated. In my view this has occurred for two reasons. First,...more

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

All in the Family – Introducing Family Owned Life Insurance™ (aka FOLI™)

The All in the Family podcast introduces Family Owned Life Insurance™ or (FOLI™). FOLI™ is a specialty use of group private placement life insurance for Family Offices. FOLI™ is a powerful product that will allow Family...more

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

Family Affair - Introducing Family Office Life Annuity (FOLA)

FOLA - Family Office Life Annuity, this solution utilized a private placement group variable deferred group contract, which provides for tax deferral. It is a powerful wealth accumulation technique. FOLA policy has customized...more

Jones & Keller, P.C.

Taking the Sting Out of Death Taxes with Dylan Metzner, Jones & Keller

Jones & Keller, P.C. on

High-net worth individuals have an opportunity to take advantage of high transfer tax exemptions if they act fast. Set to expire in 2026, unless Congress acts sooner, the time is now to implement strategies that make the most...more

Jones & Keller, P.C.

Taking the Sting Out of “Death Taxes”

Jones & Keller, P.C. on

There has been a lot of talk since September 2021 about the Build Back Better Act, which included some major tax increases. According to U.S. Senator Joe Manchin of West Virginia, this Act is dead—and I think that is the most...more

Freeman Law

Notable Tax Takeaways from President Biden’s Budget

Freeman Law on

On March 28, 2022, President Joe Biden released his FY 2023 Budget of the U.S. Government (the “Budget”). In a statement regarding the Budget, President Biden stated the following...more

Miller Nash LLP

Today in Tax: The Billionaire Minimum Income Tax and Cryptocurrency Tax Provisions in Biden’s 2023 Budget Proposal

Miller Nash LLP on

Brief commentary on recent cases, rulings, notices, and related federal tax guidance. The Billionaire Minimum Income Tax in Biden’s 2023 Budget Proposal - Biden’s proposed “top-up” tax on wealthy individuals would ensure...more

Kramer Levin Naftalis & Frankel LLP

French Tax Obligations Relating to Trusts

French trust legislation has been in effect for 10 years, during which time some early uncertainties about its application have been resolved. The connections with France that trigger application of the legislation have been...more

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