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Tax Liability Trusts

International Lawyers Network

Establishing a Business Entity in Mexico (Updated)

I. General Overview - As of 2020, Mexico has a population of 126,014,024 according to the Mexican National Institute of Statistics and Geography (Instituto Nacional de Estadística y Geografía). Covers a land area of...more

Rivkin Radler LLP

Disclaiming to Save Taxes

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It’s not enough for the founder of a closely held business to have successfully established the business. The business has to grow, not only to increase profits, but also to make it more competitive and to diversify its...more

Rivkin Radler LLP

ESBTs and the Carryover of S Corporation Losses

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Since 1995 to the present, the LLC has emerged as the entity of choice for the vast majority of entrepreneurs. This form of business entity owes its success to the flexibility and to the tax benefits that it affords its...more

Rivkin Radler LLP

Transferee Liability for Estate Tax: The Downside of Being a Beneficiary

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Death of a Parent- In the context of a family-owned business, it is often the case that the matriarch or patriarch of the family is also the chief executive of the business. They may have founded the business, or they may...more

Dunlap Bennett & Ludwig PLLC

Essential Things To Know About Trust Administration

If you have been named as the trustee of a trust, you may be wondering what your responsibilities are and how you can fulfill them. This article offers an overview of trustee duties and highlights the legal risks of serving...more

Warner Norcross + Judd

Shared Ownership of Family Cottages, Part Two: Ownership Structures for Shared Family Property

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In my last post about shared ownership of cottages, I discussed items to consider when deciding whether to create a plan for future generations to share the ownership and use of the family cottage or vacation property. Once...more

International Lawyers Network

Establishing A Business Entity In Mexico (Updated)

I. General Overview - As of 2020, Mexico has a population of 126,014,024 according to the Mexican National Institute of Statistics and Geography (Instituto Nacional de Estadística y Geografía). Covers a land area of...more

Freeman Law

Tax Court in Brief | Estate of Kalikow v. Comm’r | Estate Tax Taxation and Deductions and QTIP Trust

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Summary: Pearl B. Kalikow’s  (“Pearl”) husband died in 1990.  On January 4, 2006, Pearl passed away. The SK Trust (“Trust”) was created with the remainder of Pearl’s husband’s estate. On Pearl’s husband will it was instructed...more

Hogan Lovells

How the UK Trust Registration Service applies to trusts of real estate and changes for unit trusts

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Trustees which are UK resident, have UK assets or income which trigger a UK tax liability or directly acquire UK land on or after 6 October 2020 will generally have to register the trust with HMRC's Trust Registration Service...more

Rivkin Radler LLP

You “Placed Your Trust” In New York? You May Be Sorry You Did

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According to a report issued by the National Association of Realtors a couple of days ago, last year saw a large outmigration of people from California and New York, while Florida and Texas experienced a comparably large...more

Rivkin Radler LLP

Wendy & Jen Wreck the Movies: Addams Family Values, or “The Nanny Tried to Do It”

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What happened: Fester Addams, a wealthy bachelor, wants nothing more than to find a great love like that between his older brother Gomez and his wife Morticia, but he is too trusting and easily mislead. Following the...more

Rivkin Radler LLP

Planning for the Interest Charge on Installment Sales: Decanting a Grantor Trust?

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I recently encountered an interesting situation in which someone suggested that a grantor trust be decanted into a non-grantor trust before the end of the taxable year. The reason? To avoid the special interest charge that...more

Rivkin Radler LLP

Selling Your Business? Take the Money But Defer the Tax?

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Sale of the Business- Imagine Client has just received an attractive, all cash offer for the sale of their business; there is no financing contingency. The buyer has proposed a cash-free and debt-free deal....more

Cadwalader, Wickersham & Taft LLP

Haworth: Residency Tie-Breaker Tests in a ‘Round the World’ Tax Scheme

The UK’s First-tier Tribunal recently considered the application of the “place of effective management” residency tie-breaker test found in double tax treaties in the recent case of Haworth and others v HMRC [2022] UKFTT 34...more

International Lawyers Network

Establishing A Business Entity In Mexico (Updated)

I. General Overview - As of 2020, Mexico has a population of 126,014,024 according to the Mexican National Institute of Statistics and Geography (Instituto Nacional de Estadística y Geografía). Covers a land area of...more

Rivkin Radler LLP

Me, Myself, and I: Tax Liabilities and Dealing with One’s Own Business

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“It’s My Business”- The owner of a closely held business will often find it difficult to distinguish the business from their own person. That is certainly true for a sole proprietorship. In many cases, unfortunately, the...more

Rivkin Radler LLP

Wendy And Jen Wreck the Movies – Citizen Kane (1941) Or Deposit Money, Not Children, in the Bank

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“Legendary was the Xanadu where Kubla Kahn decreed his stately pleasure dome.” Legendary too were the colossal errors made by Mary Kane in this celebrated classic movie which follows a journalist as he tries to uncover the...more

Gray Reed

A Horse, a Horse, My Kingdom for a Horse! Lack of Proper Documentation Dooms IRS Disputes

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In real life (and especially, it seems, in tax law) it is more like to be the lack of a timely piece of paper that causes the taxpayer to lose. In the course of administering a trust, it sometimes happens that mistakes...more

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

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...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more

McDermott Will & Emery

Weekly IRS Roundup September 27 – October 1, 2021

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 27, 2021 – October 1, 2021... September 28, 2021: The IRS released a revenue...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposals for Trusts, Estates, and Retirement Accounts

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In this second blog post on the House Ways and Means Tax proposals, we address the proposed changes that will affect the taxation of trusts, estates, and retirement plans. As we discussed, on September 13, 2021, the...more

International Lawyers Network

Establishing A Business Entity In Mexico

I. General Overview - As of 2015, Mexico has a population of 119,938,473 according to the Mexican National Institute of Statistics and Geography (Instituto Nacional de Estadística y Geografía). Covers a land area of...more

Conyers

It’s About Time: Bermuda’s Approach to the Rule against Perpetuities

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Disapplying the perpetuity period of a trust can allow deceased settlors to extend their influence down many future generations, almost indefinitely. However, the hand of the deceased settlor can be seen as benign and...more

BCLP

Extension of UK trust register limited for non-UK resident trusts with no UK tax liability

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Non-UK resident trusts where all the trustees are non-UK resident and where the trust has no UK tax liability or directly-held UK assets will not have to register on the UK trust register simply because they enter into a...more

Jones Day

IRS to Begin Examination of Hundreds of High-Wealth Individuals Starting July 15

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The Internal Revenue Service ("IRS") announced that as soon as it reopens its collection and examination functions on July 15, it will immediately begin the examination of hundreds of high-income individuals and private...more

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