#AssetProtection: United States Income Tax Treaties – A to Z
The United States has tax treaties with a number of foreign countries. Under these treaties, residents (not necessarily citizens) of foreign countries are taxed at a reduced rate, or are exempt from U.S. taxes on certain items of income they receive from sources...#AssetProtection: Global Wealthy Are Getting Richer—And Older
As for the UHNW population itself, the richest are getting richer, older and more male. UHNW women decreased by 3 percent, and their total wealth decreased by about 14 percent, a phenomenon the study indicates is partially a result of increased reliance on inherited...#AssetProtection: Inheritance Taxes under IRC 2801
Section 2801 Inheritance Tax Under Section 2801(a), a U.S. domiciliary (or a U.S. resident trust) who receives a gift or bequest from a covered expatriate (CE) is subject to a tax equal to the fair market value of the covered gift or bequest, multiplied by the highest...#AssetProtection: What the Rich Are Doing Now to Reap Trump’s Tax Bonanza
The strategy is all the more powerful if tax rates drop. Why finalize the sale of a business in 2016 when there’s a chance you’ll be able to keep more of the proceeds for yourself down the line? “This is an exercise we normally go through,” said Michael...#AssetProtection: Tax and Wealth Planning Implications of a Trump Presidency
Transfer Tax Related Proposals Repeal the gift, estate tax and the generation-skipping transfer taxes, establishing in their place a carryover basis for appreciated property, subjecting beneficiaries to income tax on the gains when they dispose of the property in the...#AssetProtection: When People Laughed At The Idea Of #Trump Actually Being Elected President! Compilation – YouTube
Dear Wealth Manager, You cannot take care of your clients by simply regurgitating what you hear from the mainstream press, or the mainstream financial press, or even your clients. Get out and mingle with The People.#AssetProtection: What to expect from President-Elect Donald Trump | STEP
He proposes to eliminate estate and gift tax and to tax capital gains held until death with a USD5 million exemption (for an individual filer).With regard to individual taxation, Trump proposes to have three income tax thresholds (as opposed to the existing...#AssetProtection: You Do Not Want to Be On the Radar of the IRS Wealth Squad
It’s called the Global High Wealth Industry Group, and it falls under the Internal Revenue Service’s Large Business and International Division. It’s also been called “The Wealth Squad.” The unit, launched in 2010, aims to “take a...#AssetProtection: Estate Tax Debate: Should it Stay or Go?
On Sept. 8, 2016, the estate tax celebrated its 100th birthday. Over the past century, practitioners, lawyers and even laypersons have voiced their opinions on whether the estate tax should be retained or repealed.Not to be outdone, we asked two of our esteemed board...#AssetProtection: 2017 Promises Only Uncertainty for HNW Clients
For many clients in the mid-range, we can pretty much take care of the issue in the first paragraph below with Clayton election planning. (HNW clients may benefit from other advanced techniques such as NING trusts.) The issue in the second paragraph below (changes to...#AssetProtection: New Jersey Repeals Estate Tax
Under the new statute, the New Jersey estate tax exemption will be $2 million during the year 2017, and it will be repealed beginning in 2018. The New Jersey inheritance tax, which applies to inheritances received by non-family members, remains in effect....#AssetProtection: What is an ILIT?
The below article is very superficial. For example, although having the trustee originally purchase the insurance is optimal, there are several other ways to transfer the insurance policy into the trust. Also, ILITs are great for asset protection even if they are...#AssetProtection: Section 2704 Proposed Regs Action Steps for High Net Worth Families
Summary of Planning Action Steps Begun in 2003, Treasury took 13 years to draft these regulations, yet several material uncertainties exist. Until clarified, protect clients conservatively by: Completing contemplated and partial prior transfers. Modifying entity...#AssetProtection: #EstatePlanning Attorney to Use Time Travel in New Post-Mortem Planning Service
Wouldn’t it be nice to be able to go back and fix an estate plan before death or incapacity of the grantor? Protective Law Corporation will be very pleased to offer such post-mortem estate planning, and we will add it to our pricing sheet just as soon as the...#AssetProtection: Ten Critical Differences in the Democratic and Republican Proposed Tax
As the 2016 presidential election nears, the tax policies of the two major candidates have come into sharper focus. We’ve compiled the most critical aspects of the tax proposals that have emerged from the presidential candidates. Source: Ten Critical Differences...#AssetProtection: IRS Releases 2017 Estate & Gift Tax Exclusion Amounts (Rev Proc 2016-55)
IRS has released Revenue Procedure 2016-55 outlining 2017 estate tax exclusion and other exemption amounts relevant to estate planning, as follows: The annual gift exclusion remains at $14,000 The basic exclusion amount (for determining unified credit against gift and...#AssetProtection: IRS Takes Aim at Common Family Biz Valuation Discounts
Proposed changes to the 2704 regs will not be finalized until well into next year, most likely, and if Hillary is elected you may not discover how badly you needed the discounts until she gets her lower exclusions several years from now — but the critical point...#AssetProtection: Pre-Election Estate Tax Proposals — Clinton vs. Trump
What Practitioners Should Do? There are a number of steps that practitioners should consider taking now, even though all of this is up in the air: Communicate with and inform both current active clients and even inactive clients. It might generate interest and...#AssetProtection: Urgent — A lot of families may soon get whipsawed on estate tax (PERFECT STORM)
Tell a friend, please — you may have seen me and other estate planning attorneys blogging recently on proposed changes to Section 2704 regulations taking effect at the end of this year. While these changes affect the kind of estate tax avoidance planning that we...#AssetProtection: #EstatePlanning Blunders — Philip and Helen Wrigley
Bad planning led to $40 million estate tax bill forcing heirs to sell stock, Chicago Cubs and Wrigley Field. If attacked, do you want to be Victor or Victim? At SacredHonor.US, we hate it when people die embarrassed. And at Protect.FM, we believe good estate plans...#AssetProtection: IRS Issues New Rev Proc 2016-49 Supporting Use of Clayton Election
Good news! The IRS just issued, moments ago, a new Revenue Procedure 2016-49, modifying Rev Proc 2001-48, removing a possible grey area in the use of the so-called Clayton election for flexible and comprehensive post-mortem (i.e., portability and reverse QTIP) tax...#AssetProtection: Learning Estate Planning’s Alphabet Soup
This is authored by Matt McClintock, VP of Education for WealthCounsel: I initially created this article as a resource for members of WealthCounsel, but we share it with the entire industry. To that end, I’m sharing this resource here and encourage attorneys and...#AssetProtection: Proposed 2704 Regs “Commercially Reasonable Restriction Exclusion”
The proposed Internal Revenue Code Section 2704 regulations (the “regs”) prevent taxpayers from considering a range of restrictions that could otherwise reduce the value of an interest in an entity for transfer tax purposes. These restrictions include those...#AssetProtection: The Future of Discount Planning
It would thus appear that the only type of entity that will benefit significantly from a lack of marketability or minority interest discount in the future will be one that is engaged in an active operation, that is, where the going concern value of the interest is...#AssetProtection: State Estate and Inheritance Tax Rates and Exemptions 2016
You cannot ignore death tax planning just because the federal estate tax exemption is high now. Congress can lower the exemption at any time. Even if the federal exemption remains high, you may end up moving at some point to a state that has a state-level estate or...#AssetProtection: Fresh Look at Charitable Lead Annuity Trusts
[slideshare id=56750185&doc=aac527e2-7f52-466b-8109-82432616b858-160106174411] If attacked, do you want to be Victor or Victim? At SacredHonor.US, we hate it when people die embarrassed. And at Protect.FM, we believe good estate plans protect families. We make it...#AssetProtection: Twenty Tips for Planning at the Eleventh Hour
A practitioner’s checklist for clients near death Source: Twenty Tips for Planning at the Eleventh Hour | Wealth Management If attacked, do you want to be Victor or Victim? At SacredHonor.US, we hate it when people die embarrassed. And at Protect.FM, we believe good...#AssetProtection: SMALL BUSINESS TAX PLANNING 401K PLAN
If attacked, do you want to be Victor or Victim? At SacredHonor.US, we hate it when people die embarrassed. And at Protect.FM, we believe good estate plans protect families. We make it easy for your family to attain the comfort of skill at arms. David R. Duringer, JD,...#AssetProtection: Gift Splitting and Gifts to a Spouse Via an Irrevocable Life Insurance Trust
Conclusion In order to split gifts to a trust when Mom is a beneficiary of the trust, the gifts to children must be ascertainable and severable from gifts to Mom. Unfortunately, there is ambiguity in interpreting this phrase, but the Service seems to permit gift...#AssetProtection: Lessons Learned From Hillary Clinton’s Tax Returns
Self-Employment Income The Clintons earned $10,168,272 of self-employment income in 2015 from book royalties, speaking engagements and consulting, resulting in the payment of $301,698 in self-employment tax. As self-employed taxpayers, the Clintons pay both the...#AssetProtection: Major Components of New Section 2704 Proposed Regs
The new proposed Internal Revenue Code Section 2704 proposed regulations1 contain three sets of new rules. Here’s a brief summary of each of them. Source: Major Components of New Section 2704 Proposed Regs If attacked, do you want to be Victor or Victim? At...#AssetProtection: PLR 201632014 Extension Granted to Make Portability Election
GiftLaw Note:Decedent died on Date 1, survived by Spouse. In order for Spouse to benefit from Decedent’s deceased spouse unused exemption (DSUE), Decedent’s estate was required to file Form 706 within nine months of Decedent’s death. Decedent’s estate failed to...#AssetProtection: Analysis of the New Proposed Regulations Under Code §2704
On August 4, the Treasury Department issued long-awaited Proposed Regulations (Proposed Regulations) on valuation discounts for family-owned businesses under §2704 of the Internal Revenue Code (Code). The Proposed Regulations are out for comment until a public hearing...#AssetProtection: Kill The Estate Tax To Save Jobs – YouTube
If attacked, do you want to be Victor or Victim? At SacredHonor.US, we hate it when people die embarrassed. And at Protect.FM, we believe good estate plans protect families. We make it easy for your family to attain the comfort of skill at arms. David R. Duringer, JD,...#AssetProtection: Treasury Issues Broad Proposed Section 2704 Regulations
Although the details are significant, the bottom line is that the proposed regulations would appear to eliminate almost all minority (lack of control) discounts for closely held entity interests, including active businesses owned by a family. To accomplish that,...#AssetProtection: Number of Americans renouncing citizenship (and gun rights) near record highs
Don’t be stupid, just to save on taxes. Taxes should not drive your estate plan. Among other things, this will result in a loss of your gun rights. Then again, citizenship renunciants probably don’t care about that. A total of 508 Americans renounced their...#AssetProtection: Pre-Election Estate Tax Proposals: Clinton vs. Trump
Bottom line — have a flexible plan: The election hasn’t occurred yet, so there’s certainly no way to know which candidate will win. Party platforms haven’t even been finalized. And, there’s no assurance that the winner’s proposals will be enacted. In spite of...Doorbell – YouTube
If attacked, do you want to be Victor or Victim? At SacredHonor.US, we hate it when people die embarrassed. And at Protect.FM, we believe good estate plans protect families. We make it easy for your family to attain the comfort of skill at arms. David R. Duringer, JD,...IRS Clarifies That Indirect Owners Of Disregarded Entities Are Liable For Self-Employment Tax
The IRS recently released temporary regulations clarifying that an employee of a disregarded entity is liable for self-employment tax if the employee is a partner in the partnership that owns the disregarded entity. See Treasury Decision 9766 (May 4, 2016). Source:...Photo Gallery: Top 10 Beneficiary Designation Mistakes
The beneficiary designations on financial accounts are crucial decisions that will impact the success of a financial or estate plan. Here are 10 common mistakes that advisors should discuss with their clients. Source: Photo Gallery: Top 10 Beneficiary Designation...Photo Gallery: Sun Tzu and the Art of Estate Tax Planning
About 2,500 years ago, the coolest kids wanted to be either generals or philosophers – or both – like Sun Tzu. That’s when Sun Tzu wrote his famous book of strategy, The Art of War.You may know that the book and its timeless lessons have been studied at West...The Perils of Outright Distributions and Gifts
Here are the six primary benefits of a lifetime discretionary trust: 1. Protection From Liabilities An inheritance that goes directly into the beneficiary’s pocket is readily available to pay the beneficiary’s liabilities from a car accident, in bankruptcy, or after a...U.S. Corporate Tax Inversions Explained
What Is a Tax Inversion? A tax inversion involves a corporate deal between a U.S. corporation and a foreign corporation. For this purpose, the foreign corporation purchases the U.S. corporation. These deals sometimes involve a purchase of the U.S. corporation’s stock...States Eye Wallets of Richest Residents With Income-Tax Measures
Colorado and Maine may raise taxes on top earners, while Minnesota is looking to apply the state’s Social Security tax to high incomes to care for senior citizens and people with disabilities. California voters could extend by 12 years a soon-to-expire income-tax...2016 U.S. Trust Insights on Wealth and Worth
The 2016 U.S. Trust Insights on Wealth and Worth® survey explores who the wealthy are, where they came from, how they built and are sustaining their wealth and what they want to do with it. The survey revealed common success traits that create a picture of modern day...Top Five Traits of Effective Family Philanthropy
Through our work with the Andersons, Pitcairn has seen firsthand how a family can build a lasting philanthropic legacy, and we’ve identified five key traits that contributed to their success. We believe other wealthy families can better achieve their own philanthropic...CCA 201614036 Applies 3 yr ASED to Understated Subsequent Gift Tax Return
http://leimbergservices.com/rss/Keebler-CCA201614036.mp3 A recent Chief Counsel Advice, CCA 201614036, addressed the issue of what assessment statute expiration date (ASED) period would apply in regard to gift tax returns understated due to the domino effect of...IRS Approves Another NING/DING
http://leimbergservices.com/rss/Keebler-PLR201614007.mp3 The IRS has approved another non-grantor, incomplete gift trust. NINGs, DINGs, etc., are useful to avoid high state income taxes and are also useful for asset protection. See PLR 201614007. If attacked, do you...IRS Allows Late QTIP and Reverse QTIP Elections, Allocation of GST Exemption
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