The use of private placement life insurance (PPLI) by high-net-worth individuals has generated considerable controversy over the years, with proponents arguing that it is a proper use of existing laws that provide many of the...more
1/9/2025
/ Accredited Investors ,
Estate Planning ,
Estate Tax ,
Financial Services Industry ,
High Net-Worth ,
Income Taxes ,
Insurance Industry ,
Internal Revenue Code (IRC) ,
Investment ,
IRS ,
Life Insurance ,
Liquidity ,
Private Placement Life Insurance ,
Tax Code ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax Reform
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
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
In a case of first impression, Frank Aragona Trust v. Commissioner, 142 T.C. No. 9 (Mar. 27, 2014), the Tax Court held that a trust could materially participate in a trade or business based upon the activities of the...more
5/7/2014
/ Internal Revenue Code (IRC) ,
Investment Management ,
IRS ,
Limited Liability Company (LLC) ,
Materiality ,
Real Estate Investments ,
Residual Interest ,
Tax Court ,
Tax Exemptions ,
Trustees ,
Trusts