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
PPLI is a form of variable universal life insurance. The policy is strictly available for accredited investors and qualified purchasers as defined under federal securities law....more
Este artículo relacionará los beneficios del uso de fideicomisos estadounidenses para ciertas inversiones entrantes. Fideicomisos de EE. UU., considerados fideicomisos extranjeros con fines fiscales, es una nota....more
On April 10, the Internal Revenue Service (IRS) released PLR 201515001 (Oct. 10, 2014), favorably addressing a “taxable annuity”—essentially, a deferred annuity contract supported, in part, by subaccounts, each of which...more
Guidance addresses nondiscrimination, qualified default investment alternative, and annuity safe harbor rules. On October 24, the Internal Revenue Service (IRS) and the U.S. Department of Labor (DOL) each issued...more
The Life Actuarial Task Force's Index-Linked Variable Annuities (A) Subgroup (the "ILVA Subgroup") began a fresh look at the regulatory framework for annuity products. On February 6, it held a call to review its January 15,...more
Overview - American taxpayers have approximately $4.7 trillion invested in IRAs as of 2011. Only 2 percent of these assets or $94 billion are invested in self-directed IRAs. This is a surprising result when you...more
Overview - Large institutional investors including pension plans and endowments and foundations have made significant investments in timberland over the last forty years. These same investors have also made significant...more
Originally published in Tax Management Estates, Gifts, and Trusts Journal, x, 11/08/2012. OVERVIEW - The current tax environment suffers from a lot of economic and political uncertainty. The general consensus...more