The Presumption of Innocence Podcast: Episode 44 - A Recipe for Litigation: The Simmering Conflict Surrounding ERC Claims
REFRESH Nonprofit Basics: Navigating the Complex Rules That Describe a Public Charity
Expedited Review of IRS Applications for Recognition of Exempt Status
Nonprofit Quick Tip: State Filings in New Mexico and Utah
Back to Compliance: Reinstating Tax-Exempt Status for a Charity
PODCAST: Williams Mullen's Benefits Companion - IRS Clarifies Emergency Distributions Tax Exceptions
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
Nonprofit Quick Tip: State Filings in Oklahoma and Texas
Inflation Reduction Act Tax Trends Begin to Take Shape
Advice for Nonprofit Investment Committees From an Investment Advisor June 3, 2024 Podcast
REFRESH: Loot and Private Foundation Rules – Part 2
IRS Dirty Dozen Warnings on Charitable Scams
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
Nonprofit Quick Tip: State Filings in North Carolina and South Carolina
Nonprofit Quick Tip: State Filings in Florida and Louisiana
Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
4 Key Takeaways | Harnessing the Inflation Reduction Act: Driving Investments in Renewable Energy and Carbon Reduction
Nonprofit Basics: Scholarship Grant Program IRS Approval Requirements
Nonprofit Quick Tip: State Filings in Rhode Island and New Hampshire
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Private Foundation Advocacy
September 2024 AFRs and 7520 Rate - The September 2024 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 4.8%, a decrease from the August 2024 rate of 5.2%. The September...more
The September 2024 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 4.8%, a decrease from the August 2024 rate of 5.2%. The September applicable federal rate (“AFR”) for use...more
Non-Americans who wish to purchase U.S. real estate should be aware of the tax consequences of owning real estate here. George McCormick discusses these tax issues and steps to minimize their impact....more
Many small business owners mistakenly believe business succession planning and estate planning is for those with substantial wealth. This is simply a myth which does not reflect the nature of business or home ownership....more
On June 6, 2024, the Supreme Court of the United States issued a unanimous decision in Connelly v. United States and found that life-insurance proceeds payable to a closely held business for the purpose of funding a share...more
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
The Tax Cuts and Jobs Act of 2017 (TCJA) enacted significant changes in the federal estate and gift tax laws commencing in 2018. One of the most notable changes was that the TCJA doubled the federal lifetime gift tax...more
Many closely held businesses have shareholder buy/sell redemption agreements. These agreements are critical to maintaining business continuity when a key shareholder exits the company. When the redemption agreement is...more
Non-Americans who undertake estate and trust planning for their American citizen or resident family members should be aware of the unique tax issues that face Americans and consider these issues when doing their planning....more
Estate planning and wealth transfer professionals have their eyes on the sky as the future of federal estate taxation grows increasingly nebulous. Background - The federal gift and estate tax exemption is the amount...more
Understanding the nuances of the Internal Revenue Code (I.R.C.) is crucial for effective estate planning and tax strategy. For example, estate planners must be familiar with the tax basis adjustment provisions in 26 U.S.C. §...more
It is typical to have provisions in the governing documents for your company which contemplate the death and buyout of the owners. Most often, those buyout obligations are funded by the purchase of a life insurance policy on...more
Individuals considering moving to the United States should be aware of the tax consequences of becoming a U.S. resident and take advantage of tax planning opportunities before moving here. George McCormick discusses these...more
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
Proposed Treasury Regulations (the “Proposed Regulations”) have recently been issued to update and clarify existing reporting obligations for U.S. persons who receive gifts from abroad or who are owners or beneficiaries of...more
In a unanimous decision, the Supreme Court of the United States recently determined in Connelly v. U.S. that the value of a life insurance policy must be included in the fair market value of a closely held business for...more
Amidst many recent sharply divided decisions, the United States Supreme Court (SCOTUS) on June 6, 2024 issued a rare unanimous ruling in Connelly v. United States, which addressed estate tax considerations relative to...more
The United States Supreme Court (Supreme Court) released the Connelly v. United States opinion on June 6, 2024. The opinion affirmed the Eighth Circuit's holding in favor of the IRS that a company's contractual redemption...more
On June 6, 2024, in the case of Connelly v. United States, the United States Supreme Court determined that corporate-owned life insurance proceeds used to redeem a decedent’s shares in the corporation must be included when...more
On June 6, 2024, the United States Supreme Court issued its opinion regarding Connelly, as Executor of the Estate of Connelly v. United States. This final decision will directly impact all closely held business owners that...more
The Supreme Court has just weighed in on how gift and estate taxes apply with respect to non-cash gifts in Estate of Connelly v. United States. The Court’s opinion closely follows the economics of such arrangements, but...more
The Supreme Court of the United States issued an important ruling on June 6, 2024, clarifying the federal tax consequences of certain succession plans for closely held businesses. The Court held in Connelly v. United States,...more
Connelly v. United States involved determining the fair market value of a closely-held corporation for purposes of estate taxation. A corporation, owned by two brothers, was obligated to buy back the shares of the first to...more
In Connelly v. US, 602 US ___ (6/6/2024), the US Supreme Court affirmed a decision of the US Court of Appeals for the Eighth Circuit in favor of the government concerning the estate tax treatment of life insurance proceeds...more
All U.S. closely held businesses just received a warning from the highest court in the land that they should review their succession plans (or else risk a higher tax bill for the estates of their owners). On June 6, 2024, the...more