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
Non-Americans who wish to purchase U.S. real estate should be aware of the tax consequences of owning real estate here. George McCormick discusses these tax issues and steps to minimize their impact....more
On March 25, 2024, the IRS issued proposed regulations (REG-108761-22) which, if finalized, would identify certain CRATs as listed transactions. For those unaware of the listed transaction rules, such a designation would...more
A recent Chief Counsel Advice issued by the IRS has been described by one team of estate planning experts as “the most important IRS ruling in a decade,” and it directly contradicts the prior IRS position on the issue. Should...more
There are a lot of very smart tax attorneys out there who are trying to figure out something new, and yet there’s very little innovation. Almost all techniques that we use are incremental variations of an older technique...more
This is The End- I have dreaded the year end for as long as I can remember. As a teenager and then as a young adult I associated the final quarter of the year, and especially the period beginning on Thanksgiving and...more
A strong stock market and “soft landing” have generated significant wealth this year. The gift tax, estate tax and generation-skipping transfer tax are all imposed on the fair market value of assets at the time of transfer....more
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
Over the past few years, an unprecedented number of taxpayers have been taking advantage of the historically high estate, gift, and generation-skipping transfer tax (GST tax) exemptions—currently $12.92 million for 2023 or...more
During 2022, COVID-19, the war in Ukraine, global inflation, the Tax Cuts and Jobs Act (TCJA), the uncertainty about the Build Back Better Act (BBBA), the Corporate Transparency Act (CTA), and the Inflation Reduction Act...more
The year-end is approaching, but you still have time to work on your 2022 tax planning. Consider giving to your favorite charity to make this holiday season merry. Planned charitable giving provides you a way to maximize...more
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
Cryptocurrencies are becoming a larger component of investors' portfolios, especially for millennials and Generation Z, who collectively make up 94 percent of cryptocurrency buyers. While it may seemingly be too early for...more
In 2022, the annual exclusion for Federal Gift Taxes increased to $16,000 per person per year. Although there is near-universal acceptance of the importance of gifting, there are several issues you should consider before...more
Trusts - Trusts play an important role in estate and tax planning. A trust is a fiduciary arrangement that allows a trustee to hold legal title to assets for the benefit of a beneficiary. The beneficiary is, in turn, said...more
Our annual estate and tax planning newsletter discusses certain concepts and techniques that should be considered in 2022 by our clients and friends in California. Perhaps the most important recent development was the failure...more
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
...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
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
In 2020, COVID-19, the US presidential election, the Tax Cuts and Jobs Act (the TCJA), and the Coronavirus Aid, Relief and Economic Security Act (the CARES ACT) dominated the planning landscape....more
If you have an estate that may be subject to estate tax next year, particularly if the November election results in a greatly reduced federal estate tax exemption in 2021, now is the time to remove assets from your taxable...more
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
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 4 – May 8, 2020...more
The US Treasury released Final Regulations providing guidance under Subchapter Z (the Opportunity Zone Provisions) of the Internal Revenue Code in December of 2019. The Final Regulations clarify many portions of two earlier...more
Many estate planning provisions of the Internal Revenue Code contain brackets, exemptions, exclusions, deductions, or other figures that the Internal Revenue Service (IRS) adjusts annually for inflation. Recently, the IRS...more
If one has a financial interest in, or signature authority over, foreign financial accounts with an aggregate value exceeding $10,000 at any time during the calendar year, he or she must file FinCEN Form 114, “Report of...more