The Standard Formula Podcast | Assessing Prudential Insurance Regulation in Japan
Papa Has a Brand New Bag
All in the Family – Introducing Family Owned Life Insurance™ (aka FOLI™)
TAKE A CHANCE ON ME! PART II - Embracing the Magic of Private Placement Life Insurance and Private Placement Variable Annuities
RETURN TO FOREVER - What Game Shall We Play Today?
NOWOTNY KNOWS SQUAT! Part IV Using Post-Retirement Medical Plans to Raise AUM and Sell Life Insurance
NOWOTNY ON DEATH AND TAXES EPISODE 35 USING POST-RETIREMENT MEDICAL PLANS TO RAISE AUM
NOWOTNY KNOWS SQUAT! Part 3 Using Malta Pension Plans to Raise AUM and Sell More Life Insurance
NOWOTNY KNOWS SQUAT! Part 2 Using PPLI and PPVA Annuities to Raise Assets Under Management and Sell More Life Insurance
INTRODUCING MALTA SPLIT DOLLAR
WHERE EAGLES DARE-INTRODUCING MALTA SPLIT DOLLAR
Private Placement Life Insurance Discussion Podcast
ISLA DEL ENCANTO - INTRODUCING BORICUA SPLIT DOLLAR
Isla del Encanto-Introducing Boricua Split Dollar
Everything You Need to Know About Beneficiary Designations
THE WONDER YEARS WEBINAR
The focus of this article illustrates why private placement life insurance (“PPLI”) is the best asset to utilize in the “Buy, Borrow and Die” strategy for high net worth investors including billionaires. After this article,...more
In the Soundtrack of Our Lives, one of the songs that I still get to hear from time to time on Sirius XM, is “Still the One” which was recorded and released by the band Orleans in 1976. I was in the tenth grade just to be...more
Recently (January 15th) I celebrated my sixty fifth birthday. Where did the time go? If my East German father Willy Wolfgang Nowotny were still with us, I could hear him say, “Too soon old, too late smart.” While I was never...more
The use of private placement life insurance (PPLI) by high-net-worth individuals has generated considerable controversy over the years, with proponents arguing that it is a proper use of existing laws that provide many of the...more
Recently, the U.S. Supreme Court ruled unanimously in Connelly v. United States, that the valuation of a decedent’s shares in a closely held corporation for federal estate tax purposes must include insurance proceeds received...more
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
On June 6, 2024, in the case of Connelly v. United States, the United States Supreme Court determined that corporate-owned life insurance proceeds used to redeem a decedent’s shares in the corporation must be included when...more
In Connelly v. US, 602 US ___ (6/6/2024), the US Supreme Court affirmed a decision of the US Court of Appeals for the Eighth Circuit in favor of the government concerning the estate tax treatment of life insurance proceeds...more
No matter the size of your organization, at some point in time employees leave. As we noted previously, it behooves human resources and other departments to provide departing employees with an exit letter that includes...more
Part 1: Permitted Investments and Compliance - The self-directed individual retirement account (IRA) is an increasingly popular option for an IRA account owner, especially those owners who have significant net worth and...more
The April Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.0%. The April applicable federal rate (“AFR”) for use with a sale to a defective grantor trust or intra-family loan...more
The Senate ushered in the New Year with a bang by passing SECURE 2.0 on December 22, 2022. SECURE 2.0 includes many updates to the sweeping changes brought about under 2019’s original SECURE Act legislation. The following are...more
The latest idea for attracting and retaining employees in this post-COVID-19–pandemic era of the Great Resignation and “quiet quitting” is one that was usually limited to professors in higher education: the sabbatical. ...more
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
Perhaps you are tired of reading that I grew up in the Panama Canal Zone, but it is one of the last bastions of American colonialism. Personally, I do not like the word “colonialism” because it inevitably conjures up negative...more
Hedge Fund managers previously had an unprecedented ability to defer their carried interest in the offshore hedge funds that they manage. IRC Sec. 409A put an end to those deferrals and required hedge fund managers to...more
In this video Gerry, discusses how a business can use a commercial loan from a bank or a financial institution to help finance it's business obligation in the Loan Regime Split Dollar Method and deduct the interest on the...more
Nowotny on Death and Taxes, episode 17, THE SPLIT DOLLARMINATOR! Using Commercial Lending to “Juice” the Funding of Loan Method Split Dollar Arrangements How a business can use a commercial loan from a bank or a financial...more
This article focuses on how a business can use a commercial loan to help finance a business’ obligation in a Loan Regime Split Dollar Arrangement and deduct the interest payments for its tax purposes, without running afoul of...more
My father (of blessed memory), Willy Wolfgang Nowotny, died last November at the age of 85. He was born and raised in the Saxon region of East Germany on the Czech and Polish borders. I always figured his town was the German...more
In this article we summarize the reporting requirements under IRS Form 1099-LS relating to IRC Section 6050Y “Reportable Policy Sales”. The reporting requirements apply to all Reportable Policy Sales after December 31, 2018....more
December 2019 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split-Interest Charitable Trusts - The December Section 7520 rate for use with estate planning techniques such as CRTs,...more
The Internal Revenue Service (IRS) recently released two revenue procedures that relate to the implementation of accounting method changes as a result of the revisions to Section 846 of the Internal Revenue Code of 1986, as...more
Supreme Court Ruling in North Carolina Department of Revenue v. Kimberley Rice Kaestner 1992 Family Trust, 588 U.S. [TBD] and its Relevance to Income Taxation of Accumulated Income in California Trusts - The Supreme Court...more
On November 6, 2018, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued proposed regulations that address amendments to the rules for discounting unpaid losses under section 846 that were enacted...more