Once Removed Episode 21: Passing Down the “Family Cottage” or Other Legacy Property
Business Succession Planning Podcast with Janathan Allen
M&As – Novation and Recertification
Preserving Deferred Tax Assets in a Capital Raise
Through the years, the US Tax Court has provided significant clarification on the gift tax consequences of terminating qualified terminable interest property (QTIP) trusts. Two new cases in 2024, Estate of Sally J. Anenberg...more
With the looming elections, tax planners have taken time to consider what the future of Estate and Gift Tax planning might be under the new Congress. Every new Congress considers changes to the Internal Revenue Code of 1986,...more
What is now considered as the “abusive use of partnerships,” and why would this matter to the IRS? The agency recently released IR-2024-166, which is intended to provide “new guidance to stop partnerships from using...more
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
Modern day divorce brings us assets in many forms and many of them are “pregnant” with tax consequence when they are divided. In almost all cases, couples who can’t agree on much do tend to acknowledge that money they have...more
The requirements outlined in the tax code can significantly impact an individual’s gift and estate planning, and navigating these requirements effectively is crucial. In this blog post, we will delve into gift and estate tax...more
In response to a provision in the 2021 Infrastructure Investment and Jobs Act, the Department of the Treasury and the Internal Revenue Service (IRS) have issued proposed regulations that would impose new tax reporting...more
As a family business owner, are you missing out on valuable estate and wealth transfer planning opportunities or jeopardizing your current plan altogether? Katten recently hosted a program that addressed common concerns,...more
WHAT IS CRYPTOCURRENCY? Cryptocurrency is a digital asset that is created and traded online. Miners (computer operators) establish new units of digital currency and record them on a blockchain, a string of verified public...more
Can you be held liable for a tax liability owed by another taxpayer? Yes, under certain circumstances. The IRS uses fraudulent transfer law and “transferee” liability tools to collect unpaid taxes where a taxpayer has...more
Not Selling Your Business This Year? Beginning shortly before the House Ways and Means Committee released its version of the President’s Build Back Better plan, several posts on this blog have explored the uptick in M&A...more
Act Now Before the Window of Opportunity Closes - By now you have probably heard that the House Ways and Means Committee introduced legislation a few weeks ago (see Let the Estate Tax Planning Games Begin - But Where Will...more
“President Biden and Democrats in the Congress have been working on a $3.5 trillion spending and tax package, and the details are starting to be revealed. Indeed, on Sunday, September 12th, the House Ways and Means Committee...more
In many cases, taxpayers attempt to transfer assets or property to third persons to shield those assets and property from the federal tax lien or federal tax levy. Predictably, the IRS has various tools at their disposal to...more
In PLR 202050014, the IRS ruled that a parent would not recognize taxable gain when its disregarded entity transferred a newly formed corporation’s stock to creditors in satisfaction of its debt pursuant to a “G”...more
Corporate Rate Increase? We begin this week with the Senate having passed the President’s $1.9 trillion coronavirus relief and economic stimulus plan (the “American Rescue Plan” following a marathon session during which...more
On July 31, 2020, the U.S. Internal Revenue Service (the "IRS") and the U.S. Treasury Department ("Treasury") issued proposed regulations (the "Proposed Regulations") that provide taxpayers with definitional and computational...more
At the present time, certain tax and economic conditions have converged that provide a uniquely favorable environment for some estate planning opportunities...more
On March 13, 2020, the President of the United States issued an emergency declaration in response to the ongoing COVID-19 pandemic. The Emergency Declaration instructed the Secretary of the Treasury to provide relief from tax...more
Today’s historically low interest rates and depressed asset values make this an excellent time to engage in various estate planning techniques. Current conditions present several planning opportunities for transferring wealth...more
With the 9th Circuit Court of Appeal’s recent decision in Amazon.com Inc. et al v Commissioner of Internal Revenue, upholding a U.S. Tax Court ruling rejecting a broader definition of intangible assets in the context of...more
• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more
• The U.S. House of Representatives and Senate ushered H.R. 1, the Tax Cuts and Jobs Act (the Act), through conference committee, and President Donald Trump signed the Act into law on Dec. 22, 2017. • Most of the Act's...more
As previously discussed, the IRS and Treasury identified in July eight Obama era tax regulations that are burdensome on taxpayers. The next step for Treasury was to determine what to do with these regulations, and today we...more
Last summer, we discussed the IRS’s issuance of new Proposed Regulations under Section 2704 of the Internal Revenue Code, which regulations would severely impact discounts on gifts made to family members. ...more