The Internal Revenue Service’s new private letter ruling (PLR) concerned a domestication of a Foreign Parent corporation under U.S. ownership—with a few notable twists. First, the PLR applied a substance-over-form analysis to...more
The U.S. Department of Labor (DOL) published guidance earlier this year warning fiduciaries who administer retirement plans to “exercise extreme care” when considering whether to include cryptocurrency as a plan investment...more
“I have wondered at times what the Ten Commandments would have looked like if Moses had run them through the U.S. Congress.” – Pres. Ronald Regan- That line probably describes the exasperation with which many Americans...more
The new guidance is significant given the popularity of debt exchanges as a monetization technique in conjunction with spin-offs. On October 3, 2018, the Internal Revenue Service (IRS) published Revenue Procedure 2018-53,...more
Last year’s tax bill created an incredible opportunity for tax-free investment. It permits investors to sell or exchange appreciated assets, invest the gain in just about any sort of venture within a geographically designated...more
Business owners love to hear the words “tax-free” when considering the disposition of business assets. Unfortunately, many fail to grasp that a tax-free disposition is rarely free of tax in the sense of never being taxed;...more
Roll-Over: Tax Issue - Picking up on yesterday’s discussion, how can a PEF reconcile its preference to acquire a depreciable or amortizable basis for its target’s assets while, at the same time, affording the target’s...more
For many business owners, the final step of a successful career may be the sale of their business. At that point, the investment into which the owners have dedicated so much time, effort and money is liquidated, leaving them...more
This is part two of a two-part series on Internal Revenue Code Section 1031 tax-deferred exchange transactions. The first article provided an overview of the basic rules that govern 1031 exchanges. This article describes...more
Nothing can throw a monkey wrench into an estate plan like incurring long-term care (LTC) expenses. An LTC insurance policy can offset these costs, but the premiums can be expensive. One potential source for funding LTC...more
This webinar addresses the requirements for 1031 Exchanges, the various types of 1031 Exchanges, and issues involving 1031 Exchanges in partnerships, limited liability companies and tenant-in-common situations. Please...more
Last November, Senate Finance Committee Chairman, Max Baucus, released the third package in a series of “Staff Discussion Drafts” proposing various changes to reform the Internal Revenue Code. Of course, it is likely that any...more
The Internal Revenue Service (the Service) recently released Priv. Ltr. Rul. 2013-19-009, which interprets the transaction cost regulations of Treas. Reg. §1.263(a)-5....more
In This Issue: - How to fund long-term care insurance with a tax-free exchange - Should a CRT be part of your estate plan? - The key to an effective trust is education - Estate Planning Pitfall:...more
Long-term care (LTC) insurance is a major expense, especially for someone who purchases it at or after retirement age. One potential source for funding LTC insurance premiums is a total or partial tax-free exchange of an...more