The IRS announced that it will end the Offshore Voluntary Disclosure Program (OVDP), effective September 28, 2018. The IRS is pressing taxpayers with undisclosed foreign accounts, entities and income to come forward before the September 28, 2018 deadline and become compliant. Therefore, US taxpayers who have unreported foreign assets and income have a limited amount … Continue Reading
The Internal Revenue Service (IRS) publishes a monthly update to the applicable federal rates (AFRs) and 7520 rates. Planning professionals and their clients should take note of fluctuations in these rates and be mindful of planning opportunities that come with rate changes. The AFR is calculated by the IRS under Section 1274(d) of the Internal … Continue Reading
Each year, the IRS makes inflation adjustments to numerous thresholds, exemptions, exclusions, and other amounts that affect various tax calculations under the Internal Revenue Code. For example, annual inflation adjustments apply to the standard deductions available to taxpayers for income tax purposes, the filing thresholds for each income tax bracket, the amount available for annual … Continue Reading
The IRS recently issued final regulations, effective as of Sept. 2, 2016, providing gender-neutral definitions of “spouse,” “husband,” and “wife,” and clarifying the definition of “marriage” for federal income, transfer, and employment tax purposes. Under the new final regulation section 301.7701-18(c), a marriage (same-sex or opposite-sex) will be recognized for federal tax purposes if it is … Continue Reading
In planning for the next generation, many parents struggle with the decision of whether to transfer property to their children outright or in trust. Some feel that transferring property outright is the best option when the beneficiary is competent (i.e., mature, intelligent, financially savvy, and capable of managing money and making investment decisions). A beneficiary … Continue Reading
Portability refers to the ability of a surviving spouse, to make use of a deceased spouse’s unused estate tax exclusion amount (DSUE amount). Portability was intended to simplify estate planning for married couples by eliminating the need for a bypass trust. However, in order to preserve the DSUE amount the surviving spouse must comply with … Continue Reading
A bill that would exempt aircraft management fees from the federal air transportation excise tax is advancing in the House — good news for aircraft owners who use a leasing company structure to save on state sales tax when purchasing aircraft. The bill (H.R. 3608) clarifies that fees paid to an aircraft services company to … Continue Reading
Although many people name family and friends as trustees or personal representatives in their legacy plan, it’s probably safe to assume that the people being appointed don’t have an understanding of the high level of responsibility inherent in carrying out their fiduciary duties. One of the greatest fiduciary responsibilities is payment of a trust’s or … Continue Reading
Recently, the IRS announced that the estate tax exemption amount will slightly increase in 2016, while the annual gift tax exclusion amount will remain stagnant. The estate (and gift) tax exemption amount (exemption amount) is the total amount that an individual may transfer during life, or at death, without incurring gift or estate tax on … Continue Reading
Greenberg Traurig Tax & Business Group attorneys Jonathan Forster and Todd Steinberg, along with AALU Director of Public Policy, David Hollingsworth, hosted the 2016 Heckerling Institute on Estate Planning webinar. Hollingsworth provided the political and legislative update and discussed the challenges facing the insurance industry. Forster discussed what is trending in the marketplace, including rising interest … Continue Reading
For the avid art collector, considering the future of his or her art collection as a part of their legacy is often a difficult task. Art is a deeply personal asset. It can reflect an owner’s passion and the life he or she lived, but as an art collection grows in value, a collector must … Continue Reading
We previously wrote about how a recently passed Texas bill (S.B. 1396) will allow certain in-state aircraft purchases to qualify for a resale exemption from sales tax, with the tax instead applied to later leasing contract payments. Now, a new IRS Chief Counsel memo says that an aircraft leasing partnership that trades in an aircraft that … Continue Reading
If the thought of filing your income tax return brings you an intense feeling of dread, it may be time to consider leveraging charitable giving to purposefully mitigate your tax exposure during a high-income year. Charitable lead annuity trusts, private foundations, and donor advised funds are three legacy planning techniques which may help you to … Continue Reading
Greenberg Traurig attorneys, Jonathan Forster and Todd Steinberg, along with AALU Director, David Hollingsworth, provided an informative webinar discussing 2015 year-end tax planning. To listen to the webinar, please click here.… Continue Reading
Pursuant to a new law that Congress is expected to pass in early December, the State Department could soon have the power to rescind the passports of people who have “seriously delinquent” tax debt. Taxpayers with over $50,000 of unpaid federal taxes who are not in the process of resolving their debts with the IRS … Continue Reading
