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Internal Revenue Service Death Benefits

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Husch Blackwell LLP

Unanimous Supreme Court Determines Company-Owned Life Insurance Increases Fair Market Value

Husch Blackwell LLP on

On June 6, 2024, the Supreme Court held 9-to-0 in Connelly v. United States that company-owned life insurance increases the company’s fair market value for estate tax purposes, and the company’s obligation to redeem a...more

Burns & Levinson LLP

Client Advisory: Valuing Closely-Held Stock for Estate Tax Purposes | Connelly v. US

Burns & Levinson LLP on

The issue in Connelly v. US is whether, for estate tax purposes, the value of a closely-held corporation using corporate-owned life insurance to redeem the shares of a decedent shareholder increases the value of the company...more

Gerald Nowotny - Law Office of Gerald R....

THE WONDER YEARS WEBINAR

Loan Regime Method of Split Dollar Life Insurance - This webinar covers: What is Split Dollar? Loan Method versus Economic Benefit. Leverage Split Dollar Rollout. Planning examples using Split Dollar....more

Mitchell, Williams, Selig, Gates & Woodyard,...

New PLR Addresses Special Trustee's Power to Limit or Eliminate Testamentary General Power of Appointment

IRS Rules Appointment of Special Trustee and Special Trustee’s Subsequent Exercise of Power to Limit or Eliminate Trust Beneficiary’s Testamentary General Power of Appointment Will Not Constitute Exercise or Release for...more

Gerald Nowotny - Law Office of Gerald R....

Split Dollar Shing-a-Ling! Employing the Concepts of Inter-Generational Split Dollar in Compensatory Split Dollar Arrangements

Overview - In the last ten years, life insurance producers and their counsel have quietly transferred great fortunes with minimal gift and estate taxation using intergenerational split dollar life insurance programs....more

Gerald Nowotny - Law Office of Gerald R....

Put Me in Coach! Using Split Dollar Life Insurance Plans to Compensate Division I Coaches

In August 2016, the national sports media provided details regarding the compensation package for Coach Jim Harbaugh at the University of Michigan. It comes as no surprise to anyone that Division I football and basketball...more

Pillsbury Winthrop Shaw Pittman LLP

A New Landscape - Compliance clarifications and planning opportunities for governmental and tax-exempt employers sponsoring...

On June 22, 2016, the Internal Revenue Service (IRS) published its long-awaited proposed regulations (the Proposed Regulations) under Section 457(f) of the Internal Revenue Code (the Code). Section 457(f) governs the taxation...more

McDermott Will & Emery

Review of Section 409A Proposed Regulations

On June 22, 2016, the Internal Revenue Service (IRS) issued proposed changes to the regulations under the Internal Revenue Code (Code) §409A. The Code intends to clarify or modify a wide range of very restrictive rules...more

Patterson Belknap Webb & Tyler LLP

New Proposed Regulations for Section 457(f) Nonqualified Deferred Compensation Arrangements of Non-Profit and Governmental...

The Internal Revenue Service recently released long anticipated proposed regulations (the “Proposed Regulations”) governing deferred compensation arrangements maintained by tax-exempt organizations and governmental entities...more

Bracewell LLP

The Proposed Code Section 457 Regulations Have Arrived

Bracewell LLP on

On June 22, 2016, the IRS finally issued the long-awaited proposed regulations under Internal Revenue Code (“Code”) Section 457. Code Section 457 applies to deferred compensation plans or arrangements of tax-exempt entities...more

BCLP

Good News! New 409A Regulations (Yes, Really!) – Part 3: Don’t Fear the (409A) Reaper

BCLP on

On the TV show Futurama, the aged proprietor of the delivery company Planet Express, Professor Hubert J. Farnsworth, had a habit of entering a room where the other characters were gathered and sharing his trademark line,...more

Sherman & Howard L.L.C.

Employee Benefits Advisory: New Proposed 457 Regulations May Impact Deferred Compensation Arrangements Maintained by Tax-Exempt...

On June 21, 2016, concurrent with its issuance of proposed regulations under Code section 409A, the IRS also issued proposed regulations under Code section 457, which address deferred compensation arrangements covering...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Executive Compensation and Benefits Alert: IRS Issues New Section 409A Guidance"

In an unexpected development, on June 21, 2016, the IRS issued proposed regulations that clarify and modify the final regulations issued in 2007 and the proposed income inclusion regulations issued in 2008. In many cases,...more

Littler

IRS Issues Proposed Regulations Under Code Section 457 Affecting Deferred Compensation Plans of Tax-Exempt Organizations

Littler on

The Internal Revenue Service recently issued proposed regulations under Section 457 of the Internal Revenue Code (the “Code”) that prescribe rules regarding deferred compensation plans sponsored by state and local governments...more

Williams Mullen

Simplified IRS Relief for Same-Sex Couples and Others

Williams Mullen on

On January 27, 2014, the Internal Revenue Service announced in Revenue Procedure 2014-18 a simplified procedure for certain estates to make a late portability election under section 2010(c)(5)(A) of the Internal Revenue Code....more

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