#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
This content is for members onlyIRS Apparently Not Requiring Form 8971 Where 706 Filed for Portability Only
The instructions for Form 8971 (report of final estate value for assets to be distributed) are not exactly clear on whether the form must be filed where an estate tax return (706) is filed merely for porting deceased spousal unused exclusion amount (DSUEA): The filing...The World’s Favorite New Tax Haven Is the United States – Bloomberg Business
After years of lambasting other countries for helping rich Americans hide their money offshore, the U.S. is emerging as a leading tax and secrecy haven for rich foreigners. By resisting new global disclosure standards, the U.S. is creating a hot new market, becoming...PATH Now Permanent for $100K Charitable Contributions from IRAs
The Protecting Americans From Tax Hikes Act of 2015 (PATH) provides long-awaited certainty for taxpayers that make charitable contributions from IRAs. The new law became effective December 18, 2015. It made permanent the IRA charitable rollover provision that allows...IRS Announces 2016 Estate And Gift Tax Limits
The amount you can leave to your heirs federal estate tax free is on the rise. Source: IRS Announces 2016 Estate And Gift Tax Limits: The $10.9 Million Tax Break – Forbes Forbes’ headline is misleading. In the last paragraph, they admit that planning for...Reassessment and Entities (Reassessment and Estate Planning, Part 3)
For a deeper understanding of this subject, please take our self-paced online course or attend one of our live seminars. All training is free. Follow @guntrust If attacked, do you want to be Victor or Victim? At SacredHonor.US, we hate for people to die...Reassessment and Individuals (Reassessment and Estate Planning, Part 2)
For a deeper understanding of this subject, please take our self-paced online course or attend one of our live seminars. All training is free. Follow @guntrust If attacked, do you want to be Victor or Victim? At SacredHonor.US, we hate for people to die...Intro to Reassessment (Reassessment and Estate Planning, Part 1)
For a deeper understanding of this subject, please take our self-paced online course or attend one of our live seminars. All training is free. Follow @guntrust If attacked, do you want to be Victor or Victim? At SacredHonor.US, we hate for people to die...Landmark Supreme Court Case: Retirement Trust Necessary for Asset Protection
Asset protection is an important benefit an estate plan can provide for your family, but oftentimes there is no such planning with respect to retirement assets. This is why I have long encouraged clients to consider a separate “Standalone Retirement...IRS Approves Another NING Trust
Want to escape high state income taxes? On March 7 the IRS in PLR 201410010 approved another NING trust (Nevada Incomplete-gift Non-Grantor Trust), which is incomplete for transfer tax purposes while remaining a non-grantor trust for income tax purposes. This trust,...Irrevocable Trusts in California
An irrevocable inter vivos trust (IRT) is a trust created during the settlor’s lifetime, over which settlor retains no power to alter, amend or revoke. Although RLT’s typically become irrevocable on the settlor’s death, they are not called irrevocable trusts. Trusts...Gift Tax and Exclusions
Gift Tax Without the gift tax, families could avoid estate tax by making lifetime transfers to children, and gifts to children in a lower income tax bracket could reduce income tax as well. To the extent gift tax applies, these goals are frustrated. The gift tax is...Generation-Skipping Transfer Tax
Much as the gift tax is designed to frustrate avoidance of estate tax, the generation-skipping transfer (GST) tax is designed to deal with transferors who may attempt to avoid both estate and gift tax at successive generations by making transfers to recipients two or...Estate Tax Update
The American Taxpayer Relief Act of 2012 (ATRA) was passed on January 1, 2013, and was signed into law on January 2, 2013. The changes are often referred to as “permanent” because there are no sunset provisions. However, the Obama Administration has already proposed...Estate Planning and Basis Step Up
A primer on basis step up and estate planning: When you sell an item of property, you generally pay tax on the capital gains. This tax is applied to the excess of the sale price over your tax basis in the property. Your basis is generally the purchase price, perhaps...Disclaimer Trusts and the Clayton Alternative
DISCLAIMER TRUST The disclaimer trust is a common form of planning, used as an alternative to funding a bypass trust with a marital deduction formula in order to utilize a decedent’s applicable exclusion amount. (Use of a formula generally makes sense only if...CRUMMEY POWERS AND THE IRS
Annual exclusion gifts are often used to provide seed money for an estate freeze technique, or for payment of premium on a trust-owned life insurance policy, or to transfer fractional ownership in an asset (such as a limited partnership) in order to obtain valuation...
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