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Internal Revenue Code (IRC) Beneficiaries Shareholders

Cole Schotz

Death, Taxes and Shareholder Agreements: Lessons from the Connelly Case

Cole Schotz on

Recently, the U.S. Supreme Court ruled unanimously in Connelly v. United States, that the valuation of a decedent’s shares in a closely held corporation for federal estate tax purposes must include insurance proceeds received...more

Husch Blackwell LLP

Unanimous Supreme Court Determines Company-Owned Life Insurance Increases Fair Market Value

Husch Blackwell LLP on

On June 6, 2024, the Supreme Court held 9-to-0 in Connelly v. United States that company-owned life insurance increases the company’s fair market value for estate tax purposes, and the company’s obligation to redeem a...more

Pillsbury - Propel

Estate Planning for Founders - Part II: Planning with Qualified Small Business Stock

Pillsbury - Propel on

This is the second of a four-part series focusing on estate planning fundamentals for founders. This article will address an important topic for owners of Qualified Small Business Stock (QSBS) as defined in Section 1202 of...more

Rivkin Radler LLP

Trust Beneficiary Engages In Like Kind Exchange Using Trust Property

Rivkin Radler LLP on

It is a basic principle of the income tax that the gain or loss realized by a taxpayer from the conversion of property into cash, or from the exchange of property for other property that differs materially in kind from the...more

Burr & Forman

The New Section 199A 20% “Profit Deduction” for Pass-Through Businesses: The Undecided Issue of Owner Compensation

Burr & Forman on

Under the Tax Cuts and Jobs Act, Congress is now offering a new 20% deduction for “pass-through” businesses – i.e. businesses that are not corporations. With the corporate tax rate being reduced under the new law to a flat...more

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