News & Analysis as of

Tax Deferral

Fleurinord Law PLLC

Shohei Ohtani’s $700M Tax Deferral Strategy: What High-Income Earners Must Know

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Let’s be real—when you hear someone landed a $700 million deal, your first thought probably isn’t taxes. But Shohei Ohtani’s record-breaking contract with the Los Angeles Dodgers has become ground zero in a growing tax policy...more

Barnea Jaffa Lande & Co.

Knesset Committee Approves Bill Easing Tax Relief in Restructuring

The Knesset Finance Committee approved a draft bill for second and third readings to ease the conditions for tax relief during corporate restructuring. The bill was first published in the initial draft bill within the tax...more

Bowditch & Dewey

Do the Retirement Plan Provisions in Your Trust Still Align with Your Estate Planning Goals Following Updates to the SECURE Act?

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Following the IRS’ finalization of the SECURE Act regulations on July 18, 2024, it is a good time to review the retirement benefit provisions of your trust to make sure they still align with your estate planning goals....more

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

Still the One! – The Use of Private Placement Life Insurance in Tax Planning for Trial Attorneys with Contingency Fee Income

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

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

Barnea Jaffa Lande & Co.

Phantom Stock: A Strategic Tool for Equity Incentivization

In the contemporary landscape of talent management, organizations face major challenges in recruiting and retaining top-tier professionals. Equity incentive mechanisms have emerged as a sophisticated strategy to cultivate...more

Levenfeld Pearlstein, LLC

Practical 1031: What is an Internal Revenue Code Section 1031 Like-Kind Exchange?

Question: What is an Internal Revenue Code Section 1031 Like-Kind Exchange? Answer: Section 1031 of the Internal Revenue Code allows a taxpayer who owns business or investment real estate to “exchange” the real estate the...more

Williams Mullen

[Event] 2024 Fall Tax Forum - November 20th, Richmond, VA

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Join Williams Mullen attorneys for our Fall Tax Forum on Wednesday, November 20th, where our speakers will present on certain federal income tax issues with respect to real property transactions including 1031 exchanges, drop...more

Amundsen Davis LLC

Losing Land to Eminent Domain? Plan for Tax Consequences Using an Internal Revenue Code Section 1033 Exchange

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Under general tax rules, if the government takes your property through eminent domain and pays you condemnation proceeds, you may have to pay capital gains (or any depreciation recapture) tax if the condemnation proceeds...more

Levenfeld Pearlstein, LLC

A Tale of Two DSTs: Beware of Confusing 1031 DSTs with 453 DSTs

Real estate investors may be familiar with the acronym DST, which in the context of Internal Revenue Code Section 1031 like-kind exchanges, refers to a Delaware Statutory Trust. A 1031 DST is a vehicle by which a seller of...more

Porter Hedges LLP

Middle Market M&A Planning: What is Rollover Equity?

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The term “rollover equity” is frequently used in discussions about the sale of middle market companies (which often is described as meaning companies with enterprise values from $10 million to $1 billion[1]), but frequently...more

Mayer Brown

ESOP Update: Installment Sales Rules Save ESOP Footfall in Berman v. Comm’r

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Berman v. Comm’r,  released on July 16, 2024, is a great example of making lemonade when life hands you a lemon. Although the taxpayers lost the federal income tax deferral of a stock sale to an employee stock ownership plan...more

Bricker Graydon LLP

“S” Corp? Law Change May Make an ESOP More Appealing

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The SECURE 2.0 Act of 2022 (“SECURE 2.0”) made numerous changes to the complex web that makes up U.S. retirement plan laws. Of interest to S corporations that may be considering an employee stock ownership plan (“ESOP”) is...more

Rivkin Radler LLP

The Supreme Court’s Non-Opinion On The “Realization” of Income – A Lost Opportunity?

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In less than four months, the citizens of the United States will be electing their next President to a four-year term. They will also be deciding which of the two major political parties will “control” the Senate, the House,...more

Holland & Knight LLP

IRS Rules 3 Utilities Cannot Reduce NOL Carryforwards for Tax Allocation Payments

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Following the initial public release of private letter ruling (PLR) 20242002 as part of a state rate proceeding, on June 28, 2024, the IRS publicly released that ruling, as well as two companion rulings obtained by other...more

Holland & Knight LLP

Tax Planning Prevails in Parkway Gravel Decision

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The U.S. Tax Court recently issued an opinion in Parkway Gravel Inc. v. Commissioner, Docket No. 10819-21, respecting the structure of a gravel company's sale of a land parcel known as the Freeway Pit. In finding for the...more

Holland & Knight LLP

IRS: Use of "Attrition Allowance" to Calculate Rate Base Violates Normalization Consistency Rules

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Consistent with a state commission's existing regulatory policy, a utility's rate base for the first two years of the three-year rate cycle was computed using traditional cost-of-service/rate of return principles....more

Rivkin Radler LLP

Estate, Gift, GST & Related Income Tax Proposals – What is the White House Doing?

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Earlier this week the White House released its Fiscal Year 2025 Budget. Of course, the federal government has not yet adopted a budget for the Fiscal Year 2024 even as we approach that year’s halfway mark. But I digress. The...more

Woodruff Sawyer

What Is Private Placement Life Insurance?

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Market volatility and heightened tax uncertainty have caused increased interest in private placement life insurance (PPLI) in recent years. However, those same factors have led to increased scrutiny for high-net-worth...more

Kohrman Jackson & Krantz LLP

Mastering Retirement Planning: Strategies for 401(k), IRA, and Tax-Free Growth

In addition to employer-sponsored retirement accounts such as 401(k) and 403(b) plans, many people choose to save additional retirement assets in Individual Retirement Accounts (IRAs). Regardless of your stage in life, it is...more

Burr & Forman

Potential Tax Benefits for Investments in Qualified Rural Opportunity Funds

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Among other benefits for multi-family investors, the Small Business Jobs Act provides enhanced capital gains tax savings for investments in qualified rural opportunity funds (QROF) by (i) a temporary deferral from the...more

Williams Mullen

[Webinar] M&A Series: Partnership Interests as Tax-Advantaged Currency in REIT Portfolio Transactions - November 30th, 11:00 am -...

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Equity REITs seeking to grow assets face a challenging interest rate environment and tepid equity capital markets for funding portfolio acquisitions. However, REITs can often remain active buyers in an opportunistic real...more

Fisher Phillips

2024 Employee Benefit Limits Plus 6 Best Practices for Employers

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Get Ready For The New Year Ahead - Employees can contribute more pre-tax dollars next year to their retirement savings accounts, including 401(k) and 403(b) plans, according to an IRS announcement made on November 1. Your...more

Gray Reed

The IRS is Attacking Abusive Trust Arrangements

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Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more

Davidoff Hutcher & Citron LLP

What Are 5 Ways to Defer Taxes on Highly Appreciated Real Estate?

TRUSTS & ESTATES LAW PRACTICE - Recently, home prices have been increasing and many people believe now is the time to cash in on the value of their home. Whether it’s downsizing and taking the difference or selling a second...more

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