(A)ESOP's Fables - The Income and Estate Tax-Free ESOP
Family Affair - Introducing Family Office Life Annuity (FOLA)
TAKE A CHANCE ON ME! Tax Planning During the Biden Administration
NOWOTNY KNOWS SQUAT! Part IV Using Post-Retirement Medical Plans to Raise AUM and Sell Life Insurance
NOWOTNY ON DEATH AND TAXES EPISODE 35 USING POST-RETIREMENT MEDICAL PLANS TO RAISE AUM
NOWOTNY KNOWS SQUAT! Part 2 Using PPLI and PPVA Annuities to Raise Assets Under Management and Sell More Life Insurance
INTRODUCING MALTA SPLIT DOLLAR
WHERE EAGLES DARE-INTRODUCING MALTA SPLIT DOLLAR
THE ACCIDENTAL ENTREPRENEUR PART V video
THE ACCIDENTAL ENTREPRENEUR PART V Podcast
THE ACCIDENTAL ENTREPRENEUR PART IV
THE WONDER YEARS WEBINAR
THE ACCIDENTAL ENTREPRENEUR PART III
THE ACCIDENTAL ENTREPRENEUR
WHERE HAVE YOU GONE, CHIP HILTON?
Real estate investors may be familiar with the acronym DST, which in the context of Internal Revenue Code Section 1031 like-kind exchanges, refers to a Delaware Statutory Trust. A 1031 DST is a vehicle by which a seller of...more
Berman v. Comm’r, released on July 16, 2024, is a great example of making lemonade when life hands you a lemon. Although the taxpayers lost the federal income tax deferral of a stock sale to an employee stock ownership plan...more
Consistent with a state commission's existing regulatory policy, a utility's rate base for the first two years of the three-year rate cycle was computed using traditional cost-of-service/rate of return principles....more
Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more
It’s Complicated- The Code includes a number of complex rules that are aimed at those overseas business and investment activities of U.S. taxpayers that Congress has determined may result in the improper deferral or...more
The Senate ushered in the New Year with a bang by passing SECURE 2.0 on December 22, 2022. SECURE 2.0 includes many updates to the sweeping changes brought about under 2019’s original SECURE Act legislation. The following are...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 5, 2022 – December 9, 2022...more
If the pandemic was good for anything, it was TV watching. The pandemic may become known as the golden age of television. Since I was a foreign language major (Portuguese and Spanish) at West Point (mind you out of academic...more
Most of you know by now that I grew up in the Panama Canal Zone which no longer exists as of 1999. In that respect, the transition left me as a man without a country. My father (of blessed memory) when referring to kids...more
Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
In transactions in which a Canadian corporation seeks to acquire a U.S. target entity for shares of the Canadian acquiror in a transaction intended to be tax-deferred for U.S. federal income tax purposes, the ability of U.S....more
In April 2021, President Biden announced the “American Families Plan,” which included some significant tax law changes. Among the proposed changes included in the “American Families Plan” was the increase of the tax rate that...more
On November 23, 2020, Treasury and the IRS issued final regulations governing tax-deferred exchanges of like-kind real property under Section 1031 of the Internal Revenue Code (the Code). These final regulations (T.D. 9935 )...more
As the 2020 year draws to a close, businesses should review the tax-related provisions adopted in the CARES Act and related IRS guidance with their tax advisers: EMPLOYER REFUNDABLE CREDIT AND PAYROLL TAX DEFERRAL: -...more
Background - The Internal Revenue Code (the "Code") provides the Secretary of the Treasury with the authority to delay tax deadlines in times of national emergency....more
On August 8, 2020, the President of the United States issued a Presidential Memorandum directing the Secretary of the Treasury to use his authority pursuant to section 7508A of the Internal Revenue Code to defer the...more
On Aug. 8, 2020, President Trump issued a memorandum calling for the Secretary of Treasury to allow for the deferral of payroll tax withholding on the employee portion of certain payroll taxes. This memorandum is separate...more
On August 8, 2020, President Trump issued an executive order, directing the U.S. Treasury to grant employers the ability to defer the withholding, deposit and payment of certain payroll taxes as further COVID-19 tax relief....more
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
On August 8, 2020, the President issued a Presidential Memorandum directing the Secretary of the Treasury to use his authority to defer withholding, deposit, and payment of certain payroll tax obligations (the “Executive...more
On Friday August 28th the IRS issued limited guidance on the payroll tax deferral that was part of President Trump’s August 8th executive order. Under IRS Notice 2020-65 (the “Notice”), employers are not required to withhold...more
On August 8, 2020, the President directed the Secretary of the Treasury to authorize the deferment of certain payroll tax withholding, depositing, and payment obligations otherwise incurred on wages and compensation paid...more
On August 8, 2020, President Trump signed an executive memorandum (the Memo) directing Treasury Secretary Mnuchin to issue guidance deferring the withholding, deposit and payment by employers of the employee portion of...more
Under the CARES Act passed on March 27, 2020, Congress allowed employers and self-employed workers to defer payment of their portion of Social Security taxes that will accrue between March 27 and December 31, 2020. Fifty...more