News & Analysis as of

Life Insurance Tax Planning Internal Revenue Service

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

Pra Dizer Adeus (To Say Goodbye) – A Homage to Sergio Mendes and a Little Bit About Tax Planning for PPLI for Trial Lawyers

Litigation attorneys have had the ability to defer contingency fees since 1994. You are hard pressed to find another profession that has this tax advantage. Hedge fund managers have been running and winning the “Death Race”...more

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

Las Mañanitas

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

Levenfeld Pearlstein, LLC

Another Attack on Private Placement Life Insurance

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

Allen Barron, Inc.

Estate and Tax Planning for US Expatriates

Allen Barron, Inc. on

What are the most important elements of estate and tax planning for US expatriates?  Are you planning to move out of the United States?  Are you a US taxpayer who lives and works outside of the country?  What are some of the...more

Shumaker, Loop & Kendrick, LLP

The Estate Planner, November/December 2022

Rising rates spark interest in charitable remainder trusts - If you wish to leave a charitable legacy while generating income during your lifetime, a charitable remainder trust (CRT) may be a viable solution. In addition...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, Sept. 27, 2022

LEGISLATIVE LOWDOWN - Congress Advances Towards CR as Deadline Approaches. Yesterday, Senate Democrats proposed legislation to fund the federal government through Dec. 16 with the use of a continuing resolution (CR). The...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

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

THE WAY WE WERE - Using Loan Method Split Dollar to Recreate the Benefit of Tax Deferral for Carried Interest

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

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

THE SPLIT DOLLARMINATOR!

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

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

THE SPLIT DOLLARMINATOR!

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

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

THE SPLIT DOLLARMINATOR! Using Commercial Lending to “Juice” the Funding of Loan Method Split Dollar Arrangements

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

Bowditch & Dewey

Record Low Interest Rates Let You Have Your Cake and Eat It Too – Life Insurance, Investments & Intra-family Loans

Bowditch & Dewey on

At this time, unless Congress acts, the current lifetime estate tax exemption amount of $11,580,000 is set to sunset in 2025, which means that in 2026 it will revert to $5,000,000 per person, adjusted for inflation. Many...more

Foodman CPAs & Advisors

Did you know that the IRS has 59 Compliance Campaigns? Have your Audit Plan Ready!

Foodman CPAs & Advisors on

IRS Large Business and International (IRS LBI) currently has 59 Active Compliance Campaigns.  The purpose of the IRS compliance campaign strategy is to redefine large business compliance work and build a supportive...more

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