News & Analysis as of

Internal Revenue Service Private Placement Life Insurance

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Gerald Nowotny - Law Office of Gerald R....

Old Days – Memories of Equity Split Dollar in the Post-Loper Bright Era

This article focuses on the impact of the U.S. Supreme Court in Loper Bright Enterprises v. Raimondo, 603 U.S. (2024) and how it might apply to Split Dollar life insurance and possibly resurrect one of my favorite life...more

Gerald Nowotny - Law Office of Gerald R....

Pra Dizer Adeus (To Say Goodbye) – A Homage to Sergio Mendes and a Little Bit About Tax Planning for PPLI for Trial Lawyers

Litigation attorneys have had the ability to defer contingency fees since 1994. You are hard pressed to find another profession that has this tax advantage. Hedge fund managers have been running and winning the “Death Race”...more

Gerald Nowotny - Law Office of Gerald R....

Las Mañanitas

Recently (January 15th) I celebrated my sixty fifth birthday. Where did the time go? If my East German father Willy Wolfgang Nowotny were still with us, I could hear him say, “Too soon old, too late smart.” While I was never...more

Levenfeld Pearlstein, LLC

Another Attack on Private Placement Life Insurance

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

McDermott Will & Emery

Key Takeaways | Family Offices: Evolution & Efficiencies

McDermott Will & Emery on

This session of the Private Client West Coast Forum 2024 focused on recent developments, including income tax planning to support investment performance, executive compensation planning, private placement life insurance...more

Carlton Fields

Sen. Wyden Sets Sights on Private Placement Life Insurance

Carlton Fields on

On February 21, 2024, Senate Finance Committee Chairman Ron Wyden released a report on the findings from a self-styled “democratic staff investigation” into the use of private placement life insurance (PPLI) by...more

Gerald Nowotny - Law Office of Gerald R....

Take A Chance on Me! – Tax Planning During the Biden Administration

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

The Volkov Law Group

Swiss Life and Three Subsidiaries Agree to Pay Justice Department More Than $77 Million for Conspiracy with U.S. Taxpayers to Hide...

The Volkov Law Group on

In the run-up to the deadline for filing federal taxes, the Justice Department has a well-established practice of bringing tax-related enforcement cases against crooked tax preparers, fraudsters and corporate entities as an...more

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