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"God, grant me the serenity to accept the things I cannot change, courage to change the things I can, and wisdom to know the difference."- The Serenity Prayer- The first 100 days of President Trump’s administration have been...more
In January, the Department of the Treasury (“Treasury”) and Internal Revenue Service (IRS) issued proposed regulations on the catch-up contribution provisions under the SECURE 2.0 Act of 2022 (“SECURE 2.0”). While the...more
Background - Many defined contribution plans are designed to permit participants to take advantage of an increased employee contribution limit starting the year they turn 50....more
Starting in 2026, Highly Compensated Employees will have to make their Catch Up Contributions as after tax Roth deferrals. The Internal Revenue Service issued regulations to that effect, after the SECURE 2.0’s required...more
Typically, a parent wishes to treat their children equally in their estate plan and presumes they will achieve this goal by dividing all their assets into equal shares upon their death. Accordingly, they will designate their...more
The Internal Revenue Service has been busy. On Friday, January 10, 2025, the IRS issued several notices of proposed rulemaking impacting qualified retirement plans. One set of proposed rules adds to the SECURE 2.0 requirement...more
Last year, the IRS issued its long-anticipated final (and newly proposed) regulations to address SECURE 1.0 and 2.0 Act changes to the required minimum distribution (“RMD”) rules (Code section 401(a)(9)). The 2024 proposed...more
A record-breaking stock market has again generated significant wealth this year. The gift tax, estate tax and generation-skipping transfer tax are all imposed on the fair market value of assets at the time of transfer. Gifts...more
IRS reminds employers that implementing certain optional retirement plan provisions of SECURE 2.0 affect Form W‑2 and Form 1099‑R reporting starting in 2023 - The IRS recently issued Fact Sheet 2024‑18 to highlight how...more
A strong stock market and “soft landing” have generated significant wealth this year. The gift tax, estate tax and generation-skipping transfer tax are all imposed on the fair market value of assets at the time of transfer....more
Tax Litigation: The Week of May 2nd, 2022, through May 6th, 2022 DelPonte v. Comm’r, 158 T.C. No. 7 | May 5, 2022 | Holmes, J. | Dkt. Nos. 1144-05, 1334-06, 20679-09, 20680-09, 20681-09 Mighty v. Comm’r, TC Memo. 2022-44|...more
After months of speculation, 2022 began with no new federal estate and gift tax legislation. As the proposed legislation wended its way through the legislative process in 2021, the major proposed changes to federal estate...more
In this second blog post on the House Ways and Means Tax proposals, we address the proposed changes that will affect the taxation of trusts, estates, and retirement plans. As we discussed, on September 13, 2021, the...more
At the present time, certain tax and economic conditions have converged that provide a uniquely favorable environment for some estate planning opportunities...more