News & Analysis as of

Loans Tax Planning

McDermott Will & Emery

Weekly IRS Roundup March 25 – March 29, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 25, 2024 – March 29, 2024....more

WilmerHale

Commonly Considered Option Program Enhancements: Part IV - Employee Loans To Purchase Shares

WilmerHale on

Consider this fairly typical situation. Four years ago, employee Emma was granted an incentive stock option (ISO) to purchase 100,000 shares with an exercise price of $0.86 per share. Emma’s award is fully-vested and she...more

Rivkin Radler LLP

Generating Tax Losses as a Hobby

Rivkin Radler LLP on

Every now and then, some well-meaning colleague will ask how I spend my free time. I usually pause before responding – to gather my thoughts – which prompts them to restate their question with what they believe is greater...more

Latham & Watkins LLP

Navigating Debt Repurchases in Europe: What You Need to Know - October 2022 #2

Latham & Watkins LLP on

This Client Alert examines the key issues that typically arise in connection with debt repurchase programs. It also looks at issues applicable to both bond and loan repurchases, as well as jurisdictional issues raised by the...more

Pullman & Comley, LLC

Manufacturing Updates - Fall 2021

Pullman & Comley, LLC on

Welcome to Manufacturing Updates, Pullman & Comley’s quarterly publication that summarizes important legal developments for manufacturers. Manufacturing Updates brings together insights from attorneys across our many practice...more

Hogan Lovells

Luxembourg is modernising its securitisation law

Hogan Lovells on

The Luxembourg law on securitisation dated 22 March 2004 (the “Securitisation Law”) has been tremendously successful in providing a flexible and secure framework for Luxembourg securitisation vehicles (“SVs”), attracting a...more

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

RETURN TO FOREVER: What Game Should We Play Today? Using the Planning Power of Split Dollar Life Insurance for Income and Estate...

This article focuses on the use of Split Dollar life insurance and the use of the Leveraged Split Dollar RolloutTM technique combining the tax arbitrage of life insurance with the financial arbitrage of Split Dollar life...more

Polsinelli

IRS Ruling Takes Aim at Impact Investing

Polsinelli on

What many in the nonprofit community would have expected to be a direct road for tax exemption for a new 501(c)(3) nonprofit organization has suffered a significant set-back. On October 9th, the Internal Revenue Service...more

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

THE WONDER YEARS WEBINAR

Loan Regime Method of Split Dollar Life Insurance - This webinar covers: What is Split Dollar? Loan Method versus Economic Benefit. Leverage Split Dollar Rollout. Planning examples using Split Dollar....more

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

HEAVEN CAN WAIT

Nowotny On Death and Taxes podcast episode #24, discusses using the Loan Method of Split Dollar in the After-Life!...more

Bowditch & Dewey

Can I Withdraw Funds From My Retirement Account During COVID-19?

Bowditch & Dewey on

The Paycheck Protection Program money is spent, the temporary $600 weekly unemployment supplement is over, and we still need money. We could draw on our savings, sell investments, or take out a loan against our home. Usually,...more

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

THE WONDER YEARS WEBINAR - LOAN REGIME METHOD OF SPLIT DOLLAR LIFE INSURANCE

In this webinar you will find the answers to these important questions: 1) Why is the Loan Method of Split Dollar an important planning technique right now? 2) What is the financial and tax leverage of Loan Method Split...more

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

THE WAY WE WERE

Using the Loan Method of Split Dollar to recreate the benefit of tax deferral for Hedge Fund Managers in lieu of carried interest in their offshore fund.#splitdollar #ppli #estateplanning #financialadvisors #finance...more

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

THE WAY WE WERE

Nowotny On Death and Taxes, episode #20, The Way We Were is about using the Loan Method of Split Dollar to recreate the benefit of tax deferral for hedge fund managers. #splitdollar #ppli #hedgefundmanagers #estateplanning...more

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

THE WAY WE WERE - Using Loan Method Split Dollar to Recreate the Benefit of Tax Deferral for Carried Interest

Hedge Fund managers previously had an unprecedented ability to defer their carried interest in the offshore hedge funds that they manage. IRC Sec. 409A put an end to those deferrals and required hedge fund managers to...more

Foodman CPAs & Advisors

Are Financial Institutions Creating a Corporate Governance Strategy to handle the End of Libor?

The London Interbank Offered Rate (LIBOR) expires at the end of 2021.  Used since the early 1980s, LIBOR is the most referenced global short-term interest rate, and a “standard benchmark”....more

Foodman CPAs & Advisors

What do you do if you are a Financial Institution with COVID-19 Loan Accommodations near the end?

On August 3, 2020, the Federal Financial Institutions Examination Council (FFIEC)  issued a Joint Statement on Additional Loan Accommodations Related to COVID-19 regarding loans  that are near the end of an initial loan...more

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

Mad Dogs and Panameños!

Using the Leveraged Split Dollar Rollout (LSD™ Rollout) to Terminate Loan Regime Split Dollar™ Plans Leveraged Split Dollar - low interest rate loans, tax advantage build up of life insurance policy, and a great technique to...more

Bowditch & Dewey

Record Low Interest Rates Let You Have Your Cake and Eat It Too – Life Insurance, Investments & Intra-family Loans

Bowditch & Dewey on

At this time, unless Congress acts, the current lifetime estate tax exemption amount of $11,580,000 is set to sunset in 2025, which means that in 2026 it will revert to $5,000,000 per person, adjusted for inflation. Many...more

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

It's (Not) Too Late, Baby!

Late Start Split Dollar gives you the opportunity to convert any corporate owned or individual policy into a Split Dollar Arrangement. Converting Split Dollar into a Loan Regime Method of Split Dollar. This is an opportunity...more

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

It’s (Not) Too Late, Baby! Using Late Start Split Dollar to Create Financial and Tax Leverage

I have been writing for several weeks on Split Dollar Life Insurance and specifically the Loan Regime Method of Split DollarTM. The Loan Regime Method of Split DollarTM is a planning strategy that should be on the top of the...more

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

It's (Not) Too Late, Baby!

Nowotny On Death and Taxes episode 15 titled It's (Not) Too Late, Baby!, speaks to using Late Start Split Dollar to create financial and tax leverage....more

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

Switch Hitter! Maximizing the Flexibility of Split Dollar Life Insurance to Create Maximum Financial and Tax Leverage

Switch Dollar is a financial strategy to convert an existing Split Dollar Agreement into a Loan Regime Split Dollar plan. Loan Method Split Dollar provides tremendous financial and tax leverage in the current low interest...more

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

SWITCH HITTER! Maximizing the Flexibility of Split Dollar Life Insurance to Create Maximum Financial and Tax Leverage

Switch Dollar is a financial strategy to convert an existing Split Dollar Agreement into a Loan Regime Split Dollar plan. Loan Method Split Dollar provides tremendous financial and tax leverage in the current low interest...more

Orrick, Herrington & Sutcliffe LLP

COVID-19: What Texas Local Governments and Borrowers Need to Know About Dealing with Anticipated Tax and Revenue Shortfalls

As a result of the COVID-19 virus and declining oil prices, local governments in Texas are facing sudden, unexpected, unprecedented, dramatic shortfalls or delays in a number of their core revenue streams, in some cases...more

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