The Purple Reign… in Chaos: Netflix, Secrets, and the Fight Over Prince's Legacy...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
El 10 de abril de 2024, como parte de su campaña de la Docena Sucia (“Dirty Dozen”) para 2024, el IRS emitió una advertencia a individuos de alto patrimonio con respecto a tres trampas fiscales diseñadas para ellos por...more
On 4/10/24, as part of its Dirty Dozen Campaign for 2024, the IRS issued a warning to High Net Worth Individuals regarding three tax traps designed for them by dishonest promoters and shady tax practitioners. High Net Worth...more
From time to time, we provide updates in the estate planning area. While the November 2022 federal elections resulted in a divided Congress that dampens the likelihood of major federal tax legislation, we thought this would...more
On April 5, 2023, the IRS wrapped up its Dirty Dozen 2023 list – earlier than the release of the Dirty Dozen 2022 list which was published on June 10, 2022. According to the IRS, the Dirty Dozen represents the worst of the...more
Every year, the IRS compiles a list of common scams that taxpayers may encounter – its so-called “Dirty Dozen.” Today, the Service wrapped up the annual Dirty Dozen list of tax scams for 2023 with a reminder for taxpayers,...more
President Biden recently signed into law the Secure 2.0 Act of 2022. The Act contains, in part, an expansion of the rules for qualified charitable distributions. A qualified charitable distribution (“QCD”) is a direct...more
By most accounts, 2022 has been a tumultuous year from a planning perspective: the uncertainty of the midterm elections, stock market volatility, rising interest rates and the highest level of inflation in recent history have...more
As interest rates continue to climb, taxpayers will begin to see a greater benefit from strategies that leverage higher interest rates to reduce the actuarial value of a taxable gift. The higher the rate, the more favorable...more
According to the IRS, the Dirty Dozen represents the worst of the worst tax scams. The Dirty Dozen is a list that is compiled annually by the IRS in order to alert taxpayers, tax professionals and financial institutions of...more
Earlier this year the stock market entered bear market territory. This happens when the market declines more than 20% or more from its most recent high. The market decline has been attributed to several factors including...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 31, 2022 – June 3, 2022... May 31, 2022: The IRS issued a press release, reminding...more
Delaware Clarifies “Pro-Sandbagging” Stance by Mark Tarallo and Mary Moran In almost every M&A transaction, the parties spend some time discussing (if not heavily negotiating) the right of the buyer to bring claims against...more
On January 3, 2009, an alternative currency was born, known as Bitcoin—a cryptocurrency or virtual currency secured through digital blockchain technology, allowing electronic monetary transactions from person to person...more
By using a Charitable Unitrust Remainder Trust (CRUT), philanthropic minded donors can gift to a charitable cause while maintaining a lifetime benefit. A CRUT is an irrevocable agreement that will provide an income stream to...more
In the past year, the global market capitalization of cryptocurrency has grown exponentially, reaching a high of $2.56 trillion on May 11, 2021. Coinbase, the largest cryptocurrency exchange, has more than 68 million verified...more
I have been posting my articles on JD Supra since August 2012. I am grateful to JD Supra for helping me to spread the tax gospel of Nowotny to readers. As of today, my articles have had 523,887 views. If my Mom and Dad (of...more
Last year brought with it several unexpected challenges due to the COVID-19 pandemic, including economic, social, and financial hardships that have left many in a position of extraordinary need. ...more
Part 1 of our Article addressed why a charitably-inclined client should make a gift to charity in the year of business sale. Having completed the analysis of when it is best to make a gift, some clients may hesitate to...more
Bequests and other deferred gifts are a bedrock of any successful planned giving program. The deferred nature of these types of gifts, however, can lead to complications and delays in collecting the gift....more
According to statistics 40-50 percent of all marriages end in divorce. To add insult to injury, tax reform eliminated the deductibility of alimony payments for divorce and separation agreements that are finalized or amended...more
Overview - The first installment of this article focused on the bad news regarding limitations to Stretch IRAs as a result of the SECURE Act. This segment focuses on some alternative planning uses of the Pooled Income Fund...more
The Setting Every Community Up for Retirement Enhancement Act (the SECURE Act) was signed into U.S. law on December 20, 2019. The SECURE Act makes significant changes to the administration of IRAs and other tax-deferred...more
The most impactful legislation affecting retirement accounts in decades became effective on January 1, 2020. The Setting Every Community Up for Retirement Enhancement Act (SECURE Act) made two positive changes: • It...more