THE SPLIT DOLLARMINATOR!
In this video Gerry, discusses how a business can use a commercial loan from a bank or a financial institution to help finance it's business obligation in the Loan Regime Split Dollar Method and deduct the interest on the...more
Nowotny on Death and Taxes, episode 17, THE SPLIT DOLLARMINATOR! Using Commercial Lending to “Juice” the Funding of Loan Method Split Dollar Arrangements How a business can use a commercial loan from a bank or a financial...more
This article focuses on how a business can use a commercial loan to help finance a business’ obligation in a Loan Regime Split Dollar Arrangement and deduct the interest payments for its tax purposes, without running afoul of...more
Proposed Section 382(h) regulations released this week (the Proposed Regulations) potentially would increase the scope of a corporation’s income – namely, cancellation of debt income (COD Income) - recognized after an...more
Proposed regulations under Section 163(j) governing business interest deduction limitations confirm prior guidance and expand the scope of its application in some important respects. On November 26, 2018, the Treasury and...more
On Nov. 26, 2018, the Department of the Treasury and the Internal Revenue Service issued proposed regulations under Section 163(j) of the Internal Revenue Code regarding the limitation on the deduction for business interest...more
New tax legislation was signed into law on December 22, 2017 (the Act). The Act lowers the corporate rate from a top graduated rate of 35 percent to a flat rate of 21 percent. Under the Act individuals and certain...more
On October 13, 2016, Treasury and the IRS issued important new final and temporary regulations (the “Regulations”) under section 385 of the Internal Revenue Code addressing the treatment of intercompany debt for U.S. federal...more