Top Gun: Maverick - Core Estate Plan and Gifting Basics
US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
How Tax Works - Entity Selection
TRAs: Benefits, Complexities (and Private Jets) Explained with Tax Attorney David Peck
REFRESH: Loot and Private Foundation Rules – Part 2
IRS Dirty Dozen Warnings on Charitable Scams
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
GILTI Conscience Podcast | Spotlight Series: A Conversation With Women Trailblazers in Tax
Nonprofit Quick Tip: State Filings in North Carolina and South Carolina
Once Removed Episode 19: The Step-Transaction Doctrine and the Case of Smaldino
Digital Planning Podcast Episode: Planning for Influencers
Once Removed Episode 18: The Reciprocal Trust Doctrine
Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
Charitable Planning With Guest Stephanie Hood: Navigating Complex Rules and Traps for the Unwary
The Presumption of Innocence Podcast: Episode 28 - Under the Microscope: Examining the Future of the ERC
Once Removed Episode 16: Gift and Estate Tax, Inflation Adjustments for 2024
Once Removed Episode 17: Annual Gifting to Individuals: Options, Opportunities and Pitfalls
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
The New Proposed Regulations on DAFs: Taxable Distributions and the Penalty Tax
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
When must a hedge be identified and accounted for tax purposes? Taxpayers must identity each hedging transaction and the item it hedges. A taxpayer must clearly identify a hedging transaction “before the close of the day on...more
What is the “tax character” of a hedge? A taxpayer receives ordinary gain or loss on qualified hedges that have been properly identified in accordance with Treasury Regulation § 1.1221-2. This allows a taxpayer to ensure that...more
Enterprise Risk Management is widely used in many industries and businesses. Risk managers use increasingly sophisticated approaches, methods, analytics, and frameworks to manage complex, interrelated, and interconnected...more
On March 19, 2024, Adhesion Transaction Notice No. 01/2024 (“Zero Litigation Program 2024” or the “Program”) was published, paving the way for tax settlements between taxpayers and the Brazilian Federal Revenue. Through the...more
State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more
On 8/25/23, the IRS announced that Interest rates increase for the fourth quarter 2023 would increase to 8% per year for the calendar quarter beginning 10/1/23 for taxes owed but not fully paid by individual taxpayers...more
State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. In this newsletter edition, we will briefly summarize certain state and local tax (SALT)...more
Something’s Wrong- Of late, a not insignificant number of the business owners with whom I’ve been working have raised some concern over whether they are financially prepared for the next stage of their lives. ...more
The May Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 3.0%, a sharp increase from the April rate of 2.2%. The May applicable federal rate (“AFR”) for use with a sale to a...more
President Joseph Biden signed the Infrastructure Investment and Jobs Act (IIJA) into law on November 15, 2021. The IIJA will provide funding to overhaul the country’s physical infrastructure and will serve to give the...more
Federal interest rates increased slightly for November of 2021. The November applicable federal rate ("AFR") for use with a sale to a defective grantor trust, self-canceling installment note ("SCIN") or intra-family loan with...more
The past twelve months have demonstrated that a solid estate plan, which includes steps to protect your wealth, can help you feel better prepared and provide a sense of control during times of economic uncertainty. As we...more
The 7520 rate for January 2021 remained at 0.6%. The January 2021 Applicable Federal Interest Rates can be found here. ...more
In 2017, the United Kingdom regulator overseeing the London Interbank Offered Rate (LIBOR), a benchmark for rates for short-term interbank loans, announced that all currency and term variants of LIBOR, including U.S. dollar...more
The Internal Revenue Service (IRS) has issued Revenue Procedure 2020-44 (the Revenue Procedure) providing interim guidance for taxpayers moving away from Interbank Offered Rates (IBORs) to fallback provisions issued by the...more
Top Ten Estate Planning Recommendations before the End of 2020 - If you have not already been inundated with invitations to webinars, articles and newsletters regarding the estate planning you should consider doing before...more
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
A federal judge has delivered another win for TikTok over the weekend, temporarily blocking a White House ban “on new downloads of the video-sharing network, which would have gone into effect at 11:59 p.m. in Washington.” The...more
The 7520 rate for October 2020 remained at 0.4%. The October 2020 Applicable Federal Interest Rates can be found here. ...more
The 7520 rate for September 2020 remained at 0.4%. The September 2020 Applicable Federal Interest Rates can be found here. ...more
Estate planning for vineyard and winery owners has come to the forefront during this unpredictable pandemic and in light of the upcoming general election. There may be things out of your control, but your estate plan isn’t...more
The London Interbank Offered Rate (LIBOR) expires at the end of 2021. Used since the early 1980s, LIBOR is the most referenced global short-term interest rate, and a “standard benchmark”....more