News & Analysis as of

Internal Revenue Code (IRC) High Net-Worth

Levenfeld Pearlstein, LLC

Another Attack on Private Placement Life Insurance

The use of private placement life insurance (PPLI) by high-net-worth individuals has generated considerable controversy over the years, with proponents arguing that it is a proper use of existing laws that provide many of the...more

Lippes Mathias LLP

Know Your Rights: Managing Exposure During Audits Through Legal Representation

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The 2022 Inflation Reduction Act (the “IRA”) allocated $80 billion in funding to the Internal Revenue Service (“IRS”), much of which was earmarked for increased enforcement efforts. After some starts and stops, that funding...more

Hinshaw & Culbertson LLP

Use It or Lose It: Federal Gift and Estate Tax Exemption Set to Sunset at the End of 2025

The Tax Cuts and Jobs Act (TCJA) of 2017 nearly doubled the federal lifetime gift and estate tax exemption. In 2024, this act currently allows individuals to transfer up to $13.61 million per person and $27.22 million per...more

McDermott Will & Emery

Weekly IRS Roundup July 8 – July 12, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 8, 2024 – July 12, 2024. ...more

Husch Blackwell LLP

Understanding the 2026 Changes to the Estate, Gift, and Generation-Skipping Tax Exemptions

Husch Blackwell LLP on

The Tax Cuts and Jobs Act of 2017 provided major changes to the Internal Revenue Code, specifically doubling the federal estate, gift, and generation-skipping transfer (GST) tax exemption (collectively, the exemption) from...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

McDermott Will & Emery

West Coast Forum 2023 | Key Takeaways

McDermott Will & Emery on

McDermott’s Private Client Practice led interactive discussions on a broad range of topics pertinent to ultra-high-net-worth families, their family office representatives and other advisors at our Private Client West Coast...more

McDermott Will & Emery

IRS Announces New Compliance Initiatives to Collect More Corporate Tax Using Inflation Reduction Act Funds

McDermott Will & Emery on

On October 20, 2023, the Internal Revenue Service (IRS) announced new initiatives “to ensure large corporations pay taxes owed.” These initiatives leverage the substantial additional congressional funding that was given 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

Polsinelli

IRS Says: New Goal is to Restore Fairness by Using Tax Dollars to Audit More Millionaires, Partnerships and Large Corporations

Polsinelli on

Following our initial reaction to the Internal Revenue Service's strategic operating plan to spend $80B in funding allocated from the Inflation Reduction Act, Polsinelli’s Tax attorneys continue to monitor the IRS’ compliance...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

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

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

Foster Garvey PC on

...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more

Cadwalader, Wickersham & Taft LLP

A Look at the House Ways and Means Committee’s Tax Proposals

I. Introduction - On September 15, 2021, the House Ways and Means Committee approved tax provisions for proposed inclusion in the Build Back Better Act (the BBBA). If enacted in their current form, the proposals would,...more

Goodwin

U.S. House Proposals Would Significantly Impact Estate Planning for High Net Worth Individuals If Enacted

Goodwin on

The U.S. House Committee on Ways and Means’ tax proposals would significantly impact estate planning for high net worth individuals if enacted. Gift, estate and GST exemption amounts would be decreased; grantor trusts would...more

Goulston & Storrs PC

Big Potential Tax Changes on the Horizon for Clients

Goulston & Storrs PC on

The U.S. House Ways and Means Committee released proposed budget reconciliation legislation on September 13, 2021. The bill still must complete many steps in the legislative process – including passage by the full House of...more

Pullman & Comley, LLC

Proposed Tax Law Changes Impacting Estate and Gift Taxes

Pullman & Comley, LLC on

As many people are aware, Congress is considering changes to the federal tax code to support President Biden’s Build Back Better spending plan.  As of this writing, on September 22, 2021, no bill has been enacted....more

Polsinelli

The House Ways and Means Committee Finally Provides Draft Legislative Language for the Tax Changes First Set Forth in President...

Polsinelli on

In April 2021, President Biden announced the “American Families Plan,” which included some significant tax law changes. On May 28, 2021, the United State Department of Treasury issued a report entitled “General Explanation of...more

Bodman

Pending Tax Changes: House Ways and Means Committee Tax Proposals

Bodman on

On September 13, 2021, the U.S. House of Representatives Ways and Means Committee released draft budget reconciliation legislation proposing a number of significant tax changes for businesses and for individuals....more

Holland & Knight LLP

Tax Liability Issues to Consider for High-Net-Worth Couples in Divorce

Holland & Knight LLP on

Divorce is not a topic most clients or tax advisors enjoy discussing. Nevertheless, it is important in today's day and age to advise clients, especially high-net-worth individuals with substantial assets located in the U.S....more

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