Tax Alert Tax Provisions in the Administration s Fiscal Year 2016 Budget
|
|
- Cecily Rogers
- 7 years ago
- Views:
Transcription
1 Tax Alert Tax Provisions in the Administration s Fiscal Year 2016 Budget TAX PRACTICE BOARD Stephen Brecher Stephen.Brecher@WeiserMazars.com Timothy Burley Timothy.Burley@WeiserMazars.com Jeffrey Katz Jeffrey.Katz@WeiserMazars.com Howard Landsberg Howard.Landsberg@WeiserMazars.com James Toto James.Toto@WeiserMazars.com President Obama s proposed 2016 budget contains new provisions as well as some from previous budgets it includes plans to revise the U.S. international tax system, the taxation of domestic corporations and provisions affecting individuals. We will briefly cover some of the proposals affecting both corporations and individuals. PROVISIONS AFFECTING INDIVIDUALS Long Term Capital Gains and Qualified Dividends Tax Rate The President s proposal would increase the tax rate on long term capital gains and qualified dividends to 24.2% from 20%. The 3.8% net investment income tax would continue to apply, thus increasing the top effective long term capital gains and qualified dividends tax rate to 28%. Implementation of the Buffett Rule President Obama has included the so-called Buffet Rule, calling it the Fair Share Tax. The proposal would impose a new minimum tax of30 percent of adjusted gross income (AGI) less a credit for charitable contributions, subject to certain limitations. It would begin phasing in linearly for taxpayers having $1 million of AGI ($500,000 if married filing separately), and be fully phased in at $2 million of AGI ($1 million if married filing separately).
2 Reduction in the Value of Itemized Deductions and Other Items President Obama s budget proposal would limit the value of itemized deductions to 28 percent. It would also limit the value of specified deductions or exclusions from AGI, such as tax exempt state and local bond interest and employer sponsored health insurance paid for by employers, to 28 percent. A similar limitation would also apply under the alternative minimum tax. Carried Interest Taxation The budget proposal would tax income from a carried interest held by a person who provides services to the partnership as ordinary income regardless of its characterization at the partnership level. It would also subject the income to self-employment tax. Currently, income from carried interests is often taxed as long term capital gains, depending on the income generated by the trading or investment partnership. In addition, it is currently not subject to self-employment tax. Modification of Estate and Gift Tax Provisions The President s proposal would treat a gift or bequest of appreciated property as a sale of the property. Consequently, the donor or decedent would realize a capital gain at the time of the gift or bequest. This change would eliminate the income tax free nature of a gift and the stepped up basis for appreciated assets at death. Gains on certain property would be excludable and each person would be allowed to exclude $100,000 (indexed for inflation) of other capital gains recognized by reason of death. It would also restore the gift, estate and generation skipping transfer tax rates and exemptions to their 2009 levels. Accordingly, the gift, estate and generation skipping transfer tax rate would increase to 45% from its current 40%. The estate and generation skipping transfer tax exemption would decrease to $3.5 million (not indexed for inflation) from $5.43 million while the gift tax exemption would decrease to $1 million from $5.43 million. Modify Transfer Tax Rules for Grantor Retained Annuity Trusts (GRATS) and Other Grantor Trusts The administration s proposal would require that a GRAT have a minimum term of 10 years, a maximum term equal to the life expectancy of the annuitant plus 10 years, and prohibit any decrease in the annuity during the GRAT term. In addition, the remainder interest would be required to have a value equal to the greater of 25% of the value of the assets contributed to the GRAT or $500,000 (but not more than the value of the assets contributed to the trust) at the time the interest is created. It would also prohibit the grantor from engaging in tax-free exchanges of trust assets. Additionally, with respect to sales of assets to a grantor trust of which the seller is the deemed owner for income tax purposes, the portion of the trust attributable to the property received by the trust in the transaction would be subject to estate tax at the seller s death or gift tax when the seller is no longer considered the deemed owner. The amount subject to transfer tax would be reduced by any portion of that amount that was treated as a prior taxable gift. Simplify Gift Tax Exclusion for Annual Gifts The President s proposal would eliminate the gift tax annual exclusion s present interest requirement with respect to certain gifts and impose an annual limit per donor of $50,000 (indexed for inflation) on transfers of property within a
3 new category which would include transfers in trust (other than to a trust described in section 2642(c)(2)); transfers of interests in pass through entities; transfers entirely subject to a prohibition on sale; and, other transfers of property that, without regard to withdrawal, put, or other such rights, in the donee, cannot immediately be liquidated by the donee. Limit Duration of Generation-Skipping Transfer (GST) Tax Exemption Many trusts are now formed in jurisdictions that do not contain a rule against perpetuity which means the trust can continue indefinitely. These trusts are oftentimes fully exempt from GST tax. The proposal would provide that, on the 90 th anniversary of the creation of a trust, the GST exclusion allocated to the trust would terminate. Individual Retirement Accounts The budget proposal would require employers in business for at least two years that have more than ten employees to offer an automatic IRA option to employees. Certain exceptions would apply. Small employers would be entitled to claim a temporary nonrefundable tax credit for the employer s expense associated with the arrangement and would be entitled to an additional nonrefundable credit per enrolled employee for a period of six years. Simplify Minimum Required Distribution (MRD) Rules The proposal would exempt an individual from the MRD requirements if the aggregate value of the individual s IRA and tax-favored retirement plan accumulations does not exceed $100,000. The MRD requirements would phase in for individuals with aggregate retirement benefits between $100,000 and $110,000. In addition, the proposal would unify the application of the MRD requirements for holders of designated Roth accounts and Roth IRAs by generally treating Roth IRAs in the same manner as all other tax-favored retirement accounts. Require Non-Spouse Beneficiaries of Deceased IRA Owners and Retirement Plan Participants to Take Inherited Distributions Over No More Than Five Years. Currently, minimum distributions from a retirement plan or IRA paid to a non-spouse beneficiary can be taken over the beneficiary s lifetime in certain situations and are required to be distributed based on the joint life expectancy of the participant or employee and a designated beneficiary. Under the President s proposal, non-spouse beneficiaries of retirement plans and IRAs would generally be required to take distributions over no more than five years. Exceptions would apply to certain eligible beneficiaries for whom distributions would be allowed over the life or life expectancy of the beneficiary beginning in the year following the year of the death of the participant or owner. In the case of a child, the account would need to be fully distributed no later than five years after the child reaches the age of majority. Extend Exclusion from Income for Cancellation of Certain Home Mortgage Debt Gross income generally includes income realized from the discharge of indebtedness. Currently, there is an exception for debt on a principal residence, which generally is acquisition indebtedness limited to $2 million ($1 million if married filing separately). Under this exception, taxpayers are allowed to exclude income from the discharge of principal residence debt. Discharge of principal residence debt includes full and partial reductions of the debt. The proposal would extend the exclusion from income to amounts that are discharged before January 1, 2018.
4 Tax Benefits for Education In an attempt to simplify the tax benefits available to offset higher education costs, President Obama proposes to eliminate the Lifetime Learning Credit and student loan interest deduction and replace them with an expanded American Opportunity Tax Credit (AOTC). The AOTC would be available for a longer period of time, undergraduate students who attend school less than half-time would be eligible, and a larger portion of the credit would be refundable. Reform of Child Care Tax Incentives The budget calls for the expansion of the Child and Dependent Care Credit. The maximum credit for taxpayers with children under age five would increase from $1,050 to $3,000 per child. The income levels at which the credit begins to phase down would be increased. In addition, the dependent care flexible spending account would be eliminated. PROVISIONS AFFECTING CORPORATIONS The most discussed changes proposed by the administration include modifications to the U.S. international tax system. The modifications summarized below form the administration s primary efforts to reduce taxpayers ability to shift income overseas. Imposition of a 19% Minimum Tax on Foreign Earnings of Controlled Foreign Corporations and a One-Time 14% Transition Tax Under the President s FY 2016 proposal, dividends received by a U.S. shareholder from a controlled foreign corporation ( CFC ) would be exempt from tax. However, a 19% minimum tax (with credit given for 85% of the percountry foreign effective tax rate) would make the income generated by CFCs currently taxable. In addition, as part of this transition to what has been called a quasi-territorial regime the budget imposes a one-time 14% tax on the accumulated earnings of CFCs. The revenue generated from this one-time tax on accumulated earnings would be earmarked for the Highway Trust Fund and it is believed that it would generate approximately $238.1 billion based on the estimated $2 trillion U.S. companies are currently holding offshore. Changes to Subpart F Income and the CFC Attribution Rules The proposed 19% minimum tax would not impact the tax rate applied to subpart F income, which would continue to be taxed currently at domestic U.S. corporate tax rates. However, the budget would modify some of the categories of Subpart F income. First, it would expand the definition of subpart F income to cover digital income and income earned by a CFC from the sale of property manufactured on behalf of the CFC by a related person. Second, the proposal would limit the application of exceptions to Subpart F for certain transactions that use reverse hybrid entities. Third, the proposed budget would also permanently extend the Subpart F active financing exception and look-through rules. Finally, the budget would amend the CFC attribution rules such that stock of a foreign corporation owned by a foreign person is attributed to a related United States person. Limitation on Deducting Interest Expense The budget would also seek to limit the interest expenses that are deductible against U.S. income for U.S. members of multinational groups. Under the proposal, the U.S. member s deductible interest would be limited to its proportional share of the net interest expenses reported on the group s consolidated financial statement.
5 Limiting Shifting of Income through Transfers of Intangible Property The proposal would expand the definition of intangible property under section 936 (and for purposes of sections 367 and 482) to include workforce in place, goodwill, and going concern value, and any other item owned or controlled by a taxpayer that is not a tangible or financial asset and that has substantial value independent of the services of any individual. The proposal also would clarify that where multiple intangible properties are transferred, or where intangible property is transferred with other property or services, the IRS may value the properties or services on an aggregate basis where that achieves a more reliable result. Anti-Inversion Provisions in the Budget The budget also makes significant changes to the anti-inversion rules by broadening the definition of an inversion in order to limit the ability of domestic entities to expatriate. Under the proposal, a corporation could be subject to the anti-inversion rules of the Code at a lower ownership threshold resulting in the imposition of additional tax burdens. In particular, the proposed changes include replacing the current 80% ownership test with a greater than 50% ownership test for imposing domestic taxes on the inverted corporation, and eliminating the 60% test. The proposal would also add a special rule whereby, regardless of the level of shareholder continuity, an inversion transaction would occur if (i) immediately prior to the acquisition, the fair market value of the stock of the domestic entity is greater than the fair market value of the stock of the foreign acquiring corporation, (ii) the EAG is primarily managed and controlled in the United States, and (iii) the EAG does not conduct substantial business activities in the country in which the foreign acquiring corporation is created or organized. Finally, the proposal expands the scope of the antiinversion provisions to cover the acquisition of substantially all the assets of a domestic entity. Reduction in Corporate Tax Rate In addition to changes to U.S. international taxation, the budget also contains a number of important provisions that would apply to domestic corporations and businesses. The most significant change is the reduction in the corporate tax rate from 35% to 28%. However, this reduction would be offset by a number of changes to the Code, some of which are described below, that would curtail certain taxpayer friendly provisions. Tax Incentives for Locating Jobs in the United States The proposal would create a new general business credit against income tax equal to 20% of the expenses incurred in connection with insourcing a U.S. trade or business. The credit would apply to the reduction or elimination of a trade or business currently conducted outside the United States to the extent it resulted in an increase in U.S. jobs by creating a new or similar business within the U.S. Conversely, the proposal also would disallow deductions attributable to the outsourcing of a U.S. trade or business to the extent it resulted in a loss of U.S. jobs. Make the Research Credit Permanent and Expand Renewable Energy Credits The budget also calls for making the research credit permanent for expenditures paid or incurred after December 31, 2014, as well as modifying the current method for calculating the credit and replacing it with a simplified version. The rate would be raised from 14% to 18% for expenditures paid or incurred after December 31, The proposal would also eliminate the special rate for startups and allow for the application of the credit against the alternative minimum tax (AMT). The proposal also expands the existing federal income tax incentives available for the production of electricity using wind energy, biomass, geothermal, hydropower and other facilities where construction commences before the end of
6 2015. For facilities on which construction begins after December 31, 2015 this expansion includes permanently extending the credit and making it refundable as well as eliminating the requirement that the electricity generated be sold to third parties. Require Mark-to-Market of Financial Derivatives The FY 2016 proposal would require that derivative contracts be marked to market annually with gain or loss recognized and treated as ordinary income. The proposal defines a derivative contract broadly to include any contract the value of which is determined, in whole or part, by the value of actively traded property. Accordingly, contingent debt and notes linked to actively traded property would be taxed as derivative contracts under the proposal. Repeal LIFO and LCM Methods of Accounting The proposal seeks to eliminate several tax deferral provisions. One significant example is the repeal of the Last-In, First-Out ( LIFO ) method of accounting which allows taxpayers to determine inventory values by treating the most recently acquired goods as having been sold during the year. Under the proposal, taxpayers who currently use LIFO accounting would be required to change their method of accounting to recover the gain they had deferred ratably over a 10 year period. Similarly, the proposal also calls for the repeal of the lower-of-cost-or-market ( LCM ) method which allows taxpayers to write down the value of inventories to replacement cost. Compliance with this provision would require taxpayers to change their method of accounting and report any resulting gain over a four year period. Limitation to Deferral of Gain on Like-Kind Exchanges The proposal also calls for limiting the amount of capital gain that can be deferred on real property like-kind exchanges to $1 million per year (indexed for inflation) per taxpayer. Treasury would be granted the authority to implement aggregation and related party rules. This proposed change would dramatically alter the ability of real estate investors and operators to use like-kind exchanges to defer taxable gain on the exchange of property. Art and collectibles would be excluded from the like-kind exchange provisions. Changes to Partnership Taxation The proposal would also extend the partnership basis limitation rules to nondeductible expenditures of the partnership such as charitable contributions and foreign taxes. Under current law, a partner s distributive share of partnership losses are limited by the partner s adjusted basis in the partnership at the end of the tax year. The proposal is intended to address prior interpretations of the basis limitation rules which allowed for the deduction of charitable contributions in excess of a partner s basis. Additionally, the proposal seeks to expand the definition of a substantial built-in loss to include the transfer of an interest in a partnership if the transferring partner would have an allocated net loss in excess of $250,000. In contrast, under current law the substantial built-in loss rules apply only if the partnership has a substantial built-in loss in its assets, as opposed to the individual partner. Financial Fee on Banks and Financial Entities The proposal imposes a fee on large U.S. and foreign banks and non-bank financial institutions (including insurance companies, savings and loan holding companies, asset managers, and broker-dealers) that is broadly consistent with the principles agreed to by the G-20. The fee would apply to banks and non-bank financial institutions with worldwide assets of more than $50 billion and be assessed on the value of the institution s liabilities at a rate of seven basis
7 points (.07%). The administration estimates that the fee would raise approximately $112 billion over 10 years and apply to roughly 100 financial firms. Require Use of Average Cost Method for Calculating Basis The proposal would require taxpayers to use the average cost basis method for calculating the gain from the sale of stock with a long-term holding period for securities purchased after December 31, The average cost basis method would be applied to all identical shares of portfolio stock with a long-term holding period held by the taxpayer, including stock held with a different broker or in a separate account, except for portfolio stock held in a retirement or nontaxable account. CONCLUSION The administration s FY 2016 budget calls for dramatic changes to the U.S. international tax regime, the lowering of corporate tax rates, the elimination of numerous taxpayer friendly provisions, and modifications to individual income and transfer tax provisions. Although many believe that the enactment of many of the tax provisions contained in the budget are unlikely, they may serve as a starting point for future tax reform. Richard Bloom, CPA, PFS, MST Partner PH: Richard.Bloom@WeiserMazars.com Jonah Gruda, CPA Senior Manager PH: Jonah.Gruda@WeiserMazars.com Joseph Schaedler, JD, LLM Tax Senior PH: Joseph.Schaedler@WeiserMazars.com
8 Disclaimer of Liability Our firm provides the information in this e-newsletter for general guidance only, and does not constitute the provision of legal advice, tax advice, accounting services, investment advice, or professional consulting of any kind. The information provided herein should not be used as a substitute for consultation with professional tax, accounting, legal, or other competent advisers. Before making any decision or taking any action, you should consult a professional adviser who has been provided with all pertinent facts relevant to your particular situation. Tax articles in this e-newsletter are not intended to be used, and cannot be used by any taxpayer, for the purpose of avoiding accuracy-related penalties that may be imposed on the taxpayer. The information is provided as is, with no assurance or guarantee of completeness, accuracy, or timeliness of the information, and without warranty of any kind, express or implied, including but not limited to warranties of performance, merchantability, and fitness for a particular purpose. WeiserMazars LLP is an independent member firm of Mazars Group. CONFIDENTIALITY NOTICE: The information contained in this communication may be privileged, confidential and protected from use and disclosure. If you are not the intended recipient, or responsible for delivering this message to the intended recipient, you are hereby notified that any review, disclosure, distribution or copying of this communication is strictly prohibited. If you have received this communication in error please notify the sender immediately by replying to the message and deleting it from your computer. Thank you for your cooperation. WeiserMazars LLP
Tax Provisions in Administration s FY 2016 Budget Proposals
Tax Provisions in Administration s FY 2016 Budget Proposals Compensation, Benefits, & Qualified Plans February 2015 kpmg.com HIGHLIGHTS OF TAX PROPOSALS IN THE ADMINISTRATION S FISCAL YEAR 2016 BUDGET
More informationPresident Obama's 2016 Federal Budget Proposal
President Obama's 2016 Federal Budget Proposal March 10, 2015 by Tim Steffen On the heels of his first State of the Union address to the nation after the mid-term elections, President Obama released his
More informationTax Alert 2014 Tax Planning Guidelines for Individuals & Businesses
Tax Alert 2014 Tax Planning Guidelines for Individuals & Businesses 2013 TAX PRACTICE BOARD Stephen Brecher 646.225.5921 Stephen.Brecher@WeiserMazars.com Avoid Fiscal Cliff Timothy Burley 212.375.6508
More informationTax Provisions in Administration s FY 2016 Budget Proposals
Tax Provisions in Administration s FY 2016 Budget Proposals TAX February 2015 kpmg.com TAX PROVISIONS IN THE ADMINISTRATION S FISCAL YEAR 2016 BUDGET Executive summary President Obama, on February 2, transmitted
More informationIN THIS ISSUE: July, 2011 j Income Tax Planning Concepts in Estate Planning
IN THIS ISSUE: Goals of Income Tax Planning Basic Estate Planning Has No Income Tax Impact Advanced Estate Planning Can Have Income Tax Implications Taxation of Corporations, LLCs, Partnerships and Non-
More informationFACT SHEET: Administration's FY2015 Budget Tax Proposals
FACT SHEET: Administration's FY2015 Budget Tax Proposals Today, the U.S. Department of the Treasury released the General Explanations of the Administration's FY2015 Revenue Proposals, known as the Greenbook,
More informationTax Provisions in Administration s FY 2016 Budget Proposals
Tax Provisions in Administration s FY 2016 Budget Proposals Insurance February 2015 kpmg.com HIGHLIGHTS OF INSURANCE TAX PROPOSALS IN THE ADMINISTRATION S FISCAL YEAR 2016 BUDGET KPMG has prepared a 111-page
More informationYear End Gifts and Investments
Wealth Planning Year End Tax Tips The end of every year poses a critical deadline for utilizing certain tax benefits. The following covers various items to address in your annual tax, estate, retirement
More informationGeneral Explanations of the Administration s Fiscal Year 2016 Revenue Proposals
General Explanations of the Administration s Fiscal Year 2016 Revenue Proposals Department of the Treasury February 2015 General Explanations of the Administration s Fiscal Year 2016 Revenue Proposals
More information2016 Tax Planning & Reference Guide
2016 Tax Planning & Reference Guide The 2016 Tax Planning & Reference Guide is designed as a reference and is not intended to function as tax advice. Please consult your professional accounting advisor
More informationGeneral Explanations of the Administration s Fiscal Year 2017 Revenue Proposals
General Explanations of the Administration s Fiscal Year 2017 Revenue Proposals Department of the Treasury February 2016 General Explanations of the Administration s Fiscal Year 2017 Revenue Proposals
More informationObama Administration Budget Proposals Would Expand Impact on Tax-Favored Retirement Benefits
February 9, 2015 If you have questions, please contact your regular Groom attorney or one of the attorneys listed below: David J. Ashner dashner@groom.com (202) 861-6330 Louis T. Mazawey lmazawey@groom.com
More information2013 TAX PLANNING TIPS FOR INDIVIDUALS
2013 TAX PLANNING TIPS FOR INDIVIDUALS The 2012 American Taxpayer Relief Act, which was enacted in early January 2013, was a sweeping tax package that included permanent extension of the Bush-era tax cuts
More informationHighlights of the 2010 Tax Relief Act
On December 7, 200, President Barack Obama signed into law H.R. 4853, the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 200 (the 200 Tax Relief Act). This massive bill affects
More informationH.R. 3970 Tax Reduction and Reform Act of 2007
H.R. 3970 Tax Reduction and Reform Act of 2007 I. INDIVIDUAL TAX RELIEF October 29, 2007 The combination of the general tax reductions below and full repeal of the individual alternative minimum tax (AMT)
More informationThursday, February 19 2015 WRM# 15-06
Thursday, February 19 2015 WRM# 15-06 The WRMarketplace is created exclusively for AALU Members by the AALU staff and Greenberg Traurig, one of the nation s leading tax and wealth management law firms.
More informationTax-Savvy Planning for College Expenses
3/31/14 Tax-Savvy Planning for College Expenses The American Opportunity Tax Credit Remains Available through 2017 If you are a parent with hopes of future college diplomas for your children, you are likely
More informationCrunch or Crucible? Upcoming Changes in the Federal Tax Law A Special Edition Tax Guide for Friends and Alumni of Pomona College
Upcoming Changes in the Federal Tax Law A Special Edition Tax Guide for Friends and Alumni of Pomona College Pomona College, Office of Trusts & Estates, 550 N. College Ave., Claremont, CA 91711 www.pomona.planyourlegacy.org
More informationBunting, Tripp IngleyLLP
Dear Clients and Friends, As the end of 2011 approaches, now is a good time to start year-end tax planning to minimize your individual and business tax burden. Generally, year-end tax planning involves
More informationGIFTS: THE KEY TO ESTATE TAX SAVINGS
GIFTS: THE KEY TO ESTATE TAX SAVINGS THE LAW FIRM OF ELLEN M. WINKLER 58 Atlantic Avenue Marblehead, MA 01945 Tel. 781-631-6404 Fax 781-631-7338 www.emwinklerlaw.com Estate taxes can take a significant
More informationTRADITIONAL IRA DISCLOSURE STATEMENT
TRADITIONAL IRA DISCLOSURE STATEMENT TABLE OF CONTENTS REVOCATION OF ACCOUNT... 1 STATUTORY REQUIREMENTS... 1 (1) Qualification Requirements... 1 (2) Required Distribution Rules... 1 (3) Approved Form....
More informationSPECIAL TAX NOTICE REGARDING PLAN PAYMENTS
SPECIAL TAX NOTICE REGARDING PLAN PAYMENTS This notice explains how you can continue to defer federal income tax options for your distribution from the Plan and contains important information you will
More informationBACKGROUND AND PRESENT LAW RELATED TO TAX BENEFITS FOR EDUCATION
BACKGROUND AND PRESENT LAW RELATED TO TAX BENEFITS FOR EDUCATION Scheduled for a Public Hearing Before the SENATE COMMITTEE ON FINANCE on June 24, 2014 Prepared by the Staff of the JOINT COMMITTEE ON TAXATION
More informationObama Tax Compromise APPROVED by Congress
December 17, 2010 Obama Tax Compromise APPROVED by Congress on Thursday, December 16, 2010 The $858 billion tax deal negotiated by President Obama and Republican leadership was overwhelmingly approved
More informationThursday, February 12 2015 WRM# 15-05
Thursday, February 12 2015 WRM# 15-05 The WRMarketplace is created exclusively for AALU Members by the AALU staff and Greenberg Traurig, one of the nation s leading tax and wealth management law firms.
More informationPartner's Instructions for Schedule K-1 (Form 1065)
2014 Partner's Instructions for Schedule K-1 (Form 1065) Partner's Share of Income, Deductions, Credits, etc. (For Partner's Use Only) Department of the Treasury Internal Revenue Service Section references
More informationThe Devil Is in the Details: Treasury Releases Green Book of Obama Administration FY 2013 Tax Priorities
February 22, 2012 Practice Group: Public Policy and Law The Devil Is in the Details: Treasury Releases Green Book of Obama Administration FY 2013 Tax Priorities By Michael W. Evans, Patrick G. Heck, William
More informationIn the Know December 30, 2010
In the Know December 30, 2010 On December 17, 2010, President Obama signed the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 aka the 2010 Tax Relief Act. Below we break
More informationGeneral Explanations of the Administration s Fiscal Year 2015 Revenue Proposals
General Explanations of the Administration s Fiscal Year 2015 Revenue Proposals Department of the Treasury March 2014 This document is available online at: http://www.treasury.gov/resource-center/tax-policy/pages/general
More informationCOLLIERS INTERNATIONAL USA, LLC And Affiliated Employers 401(K) Plan DISTRIBUTION ELECTION
1. EMPLOYEE INFORMATION (Please print) COLLIERS INTERNATIONAL USA, LLC And Affiliated Employers 401(K) Plan DISTRIBUTION ELECTION Name: Address: Social Security No.: Birth Date: City: State: Zip: Termination
More information2010 Partner s Instructions for Schedule K-1 (Form 1065) Partner s Share of Income, Deductions, Credits, etc. (For Partner s Use Only)
2010 Partner s Instructions for Schedule K-1 (Form 1065) Partner s Share of Income, Deductions, Credits, etc. (For Partner s Use Only) Section references are to the Internal Revenue Code unless otherwise
More informationHow do the 2016 Presidential Tax Plans Compare So Far?
How do the 2016 Presidential Tax Plans Compare So Far? 10-Year GDP Growth 10.0% 16.0% -1.0% 13.9% 15.0% -9.5% 11.5% 10-Year Capital Investment Growth 28.8% 46.6% -2.8% 43.9% 48.9% -18.6% 29% 10-Year Wage
More informationHardship distributions. A hardship distribution is not eligible for rollover.
SPECIAL TAX NOTICE REGARDING PLAN PAYMENTS 1 (Alternative to IRS Safe Harbor Notice - For Participant) This notice explains how you can continue to defer federal income tax on your retirement plan savings
More informationPartner's Instructions for Schedule K-1 (Form 1065)
2012 Partner's Instructions for Schedule K-1 (Form 1065) Partner's Share of Income, Deductions, Credits, etc. (For Partner's Use Only) Department of the Treasury Internal Revenue Service Section references
More informationTAX ASPECTS OF MUTUAL FUND INVESTING
Tax Guide for 2015 TAX ASPECTS OF MUTUAL FUND INVESTING INTRODUCTION I. Mutual Fund Distributions A. Distributions From All Mutual Funds 1. Net Investment Income and Short-Term Capital Gain Distributions
More informationIRS Issues Final and New Proposed Regulations Implementing the 3.8% Tax on Investment Income
IRS Issues Final and New Proposed Regulations Implementing the 3.8% Tax on Investment Income Final Regulations and New Proposed Regulations Implement the 3.8% Tax on Net Investment Income of Individuals,
More informationTAX RELIEF ACT UPDATED DECEMBER 29, 2010
2010 TAX RELIEF ACT UPDATED DECEMBER 29, 2010 TAX RELIEF, UNEMPLOYMENT INSURANCE RE-AUTHORIZATION, AND JOB CREATION ACT OF 2010 INTRODUCTION On December 17, 2010, President Obama signed the much-anticipated
More informationFederal Tax Policy and UNC
Federal Tax Policy and UNC Introduction Federal tax benefits for colleges and universities have become increasingly important to overall higher education policy in the United States over the past 20 years.
More informationTAX PROVISIONS IN THE AMERICAN TAXPAYER RELIEF ACT OF 2012 (ATRA) James Nunns and Jeffrey Rohaly Urban-Brookings Tax Policy Center January 9, 2013
TAX PROVISIONS IN THE AMERICAN TAXPAYER RELIEF ACT OF 2012 (ATRA) James Nunns and Jeffrey Rohaly Urban-Brookings Tax Policy Center January 9, 2013 ABSTRACT The fiscal cliff debate culminated in the passage
More informationEstate Planning With Qualified Plans
Estate Planning With Qualified Plans Gayle Evans A. Introduction Gayle Evans a member of Chinnery Evans & Nail PC, in Lee s Summit, Missouri, as well as DosterUllom, LLC, in Chesterfield, Missouri, has
More informationTax Provisions in Administration s FY 2015 Budget Proposals
TAX Tax Provisions in Administration s FY 2015 Budget Proposals March 2014 kpmg.com TAX PROVISIONS IN THE ADMINISTRATION S FISCAL YEAR 2015 BUDGET Executive summary President Obama on March 4 transmitted
More informationIN THIS ISSUE: August, 2011 j Top Income Tax Planning Ideas for 2011 and 2012
IN THIS ISSUE: Income Tax Overview Qualified Dividends Long-Term Capital Gains Ordinary Income Additional Income Tax Planning Ideas Income Shifting to Junior Generations Roth IRA Conversions NUA Planning
More informationWealthiest Families Know: 2013 & Beyond
What the Wealthiest Families Know: 2013 & Beyond Determine How Estate Planning Strategies and Life Insurance May Help You Turn Your Goals into a Wealth Legacy Whether you acquired it or inherited it, wealth
More informationShareholder's Instructions for Schedule K-1 (Form 1120S)
2015 Shareholder's Instructions for Schedule K-1 (Form 1120S) Shareholder's Share of Income, Deductions, Credits, etc. (For Shareholder's Use Only) Department of the Treasury Internal Revenue Service Section
More informationTax Alpha. Robert S. Keebler, CPA, M.S.T., AEP. Keebler & Associates, LLP 420 South Washington Street Green Bay, WI 54301.
Tax Alpha Presented by Robert S. Keebler, CPA, M.S.T., AEP Keebler & Associates, LLP 420 South Washington Street Green Bay, WI 54301 Agenda 1. Five Dimensional Tax System Ordinary Income Rates Capital
More informationTABLE OF CONTENTS PAGE GENERAL INFORMATION B-3 CERTAIN FEDERAL INCOME TAX CONSEQUENCES B-3 PUBLISHED RATINGS B-7 ADMINISTRATION B-7
STATEMENT OF ADDITIONAL INFORMATION INDIVIDUAL VARIABLE ANNUITY ISSUED BY JEFFERSON NATIONAL LIFE INSURANCE COMPANY AND JEFFERSON NATIONAL LIFE ANNUITY ACCOUNT G ADMINISTRATIVE OFFICE: P.O. BOX 36840,
More informationWealth Transfer Planning Considerations for 2011 and 2012
THE CENTER FOR WEALTH PLANNING Wealth Transfer Planning Considerations for 2011 and 2012 March 2011 The Center for Wealth Planning is part of Credit Suisse s Private Banking USA and does not provide tax
More informationLEGAL ALERT. February 16, 2011. Ready Aim Fire! FY 2012 Budget Proposals (Once Again) Target Insurance Companies
LEGAL ALERT February 16, 2011 Ready Aim Fire! FY 2012 Budget Proposals (Once Again) Target Insurance Companies On February 14, 2011, the Administration released its fiscal year 2012 budget (FY 2012 Budget).
More informationTAX RELIEF ACT EXTENDS CURRENT TAX RATES, RENEWS EXPIRING PROVISIONS AND PROVIDES NEW INCENTIVES FOR INVESTMENT
DECEMBER 2010 WWW.BDO.COM SUBJECT TAX RELIEF ACT EXTENDS CURRENT TAX RATES, RENEWS EXPIRING PROVISIONS AND PROVIDES NEW INCENTIVES FOR INVESTMENT SUMMARY CONTACT: KEVIN ANDERSON National Tax Services,
More informationEstate planning strategies using life insurance in a trust Options for handling distributions, rollovers and conversions
Estate planning strategies using life insurance in a trust Options for handling distributions, rollovers and conversions Life s better when we re connected Table of contents Find your questions review
More informationRoth IRA Disclosure Statement
Roth IRA Disclosure Statement RIGHT TO REVOKE YOUR ROTH IRA You have the right to revoke your Roth IRA within seven days of the receipt of the disclosure statement If revoked, you are entitled to a full
More informationTOWN OF NATICK OBRA 457 DEFERRED COMPENSATION GOVERNMENTAL PLAN DISTRIBUTION FORM
TOWN OF NATICK OBRA 457 DEFERRED COMPENSATION GOVERNMENTAL PLAN DISTRIBUTION FORM PARTICIPANT/ ALTERNATE PAYEE INFORMATION DISTRIBUTION REASON PAYMENT METHOD SPOUSE S CONSENT TO DISTRIBUTION (not applicable
More informationH.R. XXX Small Business Tax Relief Act of 2010
H.R. XXX Small Business Tax Relief Act of 2010 July 30, 2010 I. SMALL BUSINESS TAX RELIEF Provide small business tax relief by repealing certain information reporting requirements to corporations and to
More informationtax planning strategies
tax planning strategies In addition to saving income taxes for the current and future years, effective tax planning can reduce eventual estate taxes, maximize the amount of funds you will have available
More information2014-2015 Tax Update: Another Year For Tax Breaks By Kurt J. Kilwein, CPA, CFP, Partner and Olga Zarney, CPA, MBT, Manager
WINTER 2014-2015 2014-2015 Tax Update: Another Year For Tax Breaks By Kurt J. Kilwein, CPA, CFP, Partner and Olga Zarney, CPA, MBT, Manager Individual Taxation Many of the tax breaks which expired at the
More informationPRESENT LAW AND ANALYSIS RELATING TO TAX BENEFITS FOR HIGHER EDUCATION
PRESENT LAW AND ANALYSIS RELATING TO TAX BENEFITS FOR HIGHER EDUCATION Scheduled for a Public Hearing Before the SUBCOMMITTEE ON SELECT REVENUE MEASURES of the HOUSE COMMITTEE ON WAYS AND MEANS on May
More informationDiabetes Partnership of Cleveland s Planned Giving Guide
Diabetes Partnership of Cleveland s Planned Giving Guide Diabetes Partnership of Cleveland s Planned Giving Guide TABLE OF CONTENTS Life Insurance Gifts Page 2 Charitable Gifts of IRAs.Page 3 Charitable
More informationMedicare's New Administration Budget For Retirement and Welfare Plans
February 11, 2016 If you have questions, please contact your regular Groom attorney or one of the attorneys listed below: Michael P. Kreps mkreps@groom.com (202) 861-5415 Rachel Leiser Levy rlevy@groom.com
More informationAMENDMENT TO YOUR TRADITIONAL IRA
INDIVIDUAL RETIREMENT ANNUITY DISCLOSURE STATEMENT AMENDMENT This disclosure statement explains the rules governing a Traditional IRA. The term IRA will be used in this disclosure statement to refer to
More informationHigher Education Tax Benefits: Brief Overview and Budgetary Effects
Higher Education Tax Benefits: Brief Overview and Budgetary Effects Margot L. Crandall-Hollick Analyst in Public Finance Mark P. Keightley Analyst in Public Finance August 24, 2011 CRS Report for Congress
More informationNORTHEAST INVESTORS TRUST ROTH IRA INVESTOR S KIT
NORTHEAST INVESTORS TRUST ROTH IRA INVESTOR S KIT 125 High Street Boston, MA 02110 Telephone: 800-225-6704 Table of Contents NORTHEAST INVESTORS TRUST ROTH IRA DISCLOSURE STATEMENT...1 INTRODUCTION...1
More informationCongress Begins Work on ETI Replacement Legislation (08/01/03)
Congress Begins Work on ETI Replacement Legislation (08/01/03) Prior to the start of a month-long August recess, the House and Senate tax-writing committees began consideration of potential solutions to
More informationAmerican Taxpayer Relief Act of 2012- UPDATED
American Taxpayer Relief Act of 2012- UPDATED On January 2, 2013, the President signed the American Taxpayer Relief Act, thus ending the nation s brief stint over the fiscal cliff a confluence of expiring
More informationThe American Tax Relief Act of 2012 (HR 8, the Act )
NATIONAL CAPITAL GIFT PLANNING COUNCIL The Fiscal Cliff, Taxes and Planned Giving: Where Are We Now? Robert E. Madden Susan Leahy BLANK ROME LLP JANUARY 9, 2013 The American Tax Relief Act of 2012 (HR
More information2014 tax planning tables
2014 tax planning tables 2014 important deadlines Last day to January 15 Pay fourth-quarter 2013 federal individual estimated income tax January 27 Buy in to close a short-against-the-box position (regular-way
More informationTHE IRA CHARITABLE ROLLOVER
THE IRA CHARITABLE ROLLOVER The IRA Charitable Rollover was first added to the Internal Revenue Code of 1986, as amended, under legislation enacted in 2006. It permitted individuals to roll over up to
More informationT.W. Lewis & Co., LLC Summer 2006 PUBLICATION
T.W. Lewis & Co., LLC Summer 2006 PUBLICATION fyi: Roth IRA Conversions Taxpayers with six-figure incomes who like to plan ahead should be aware of a new provision in the recently enacted Tax Increase
More informationTHE INCOME TAXATION OF ESTATES & TRUSTS
The income taxation of estates and trusts can be complex because, as with partnerships, estates and trusts are a hybrid entity for income tax purposes. Trusts and estates are treated as an entity for certain
More informationAn Overview of The Tax Relief Act on 2010
An Overview of The Tax Relief Act on 2010 On December 17, 2010, the President signed a multi-billion dollar tax cut package, the Tax Relief, Unemployment Insurance Reauthorization and Job Creation Act
More informationA. TYPES OF PLAN DISTRIBUTIONS
SPECIAL TAX NOTICE REGARDING PLAN PAYMENTS 1 (Alternative to IRS Safe Harbor Notice - For Participant) This notice explains how you can continue to defer federal income tax on your retirement plan savings
More informationEnhance and permanently extend the research tax credit, and increase the rate of the alternative simplified research credit (ASC) from 14% to 17%.
This update covers some of the provisions being suggested in the President s new budget for fiscal year 2015. I ve highlighted the items that are of greatest importance. 2015 Tax Proposals For Businesses
More informationNORTHEAST INVESTORS TRUST. 125 High Street Boston, MA 02110 Telephone: 800-225-6704
NORTHEAST INVESTORS TRUST traditional IRA INVESTOR S KIT 125 High Street Boston, MA 02110 Telephone: 800-225-6704 Table of Contents NORTHEAST INVESTORS TRUST TRADITIONAL IRA DISCLOSURE STATEMENT...1 INTRODUCTION...1
More information10 Rules of Thumb for Trust Income Taxation Presented by Adam Scott
10 Rules of Thumb for Trust Income Taxation Presented by Adam Scott Rule #1: When in doubt, refer to the trust document; an investment policy for a trust cannot be created without it. One advantage of
More informationThe Act introduces a number of incentives, which address various aspects of the business enterprise.
A DV I S O RY October 2010 Tax Provisions of the Small Business Jobs Act of 2010: Stimulating Investment and Entrepreneurship with US$12 Billion in Tax Incentives Paid for by Corresponding Revenue Raisers
More informationClient Letter: Individual Tax Provisions of the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010
Source: Tax Legislation > 111th Congress (2009-2010) > Enacted > Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (P.L. 111-312) > Practice Tools > Client Letter: Individual
More informationPATRICK J. RUBEY & COMPANY, LTD. CERTIFIED PUBLIC ACCOUNTANTS
PATRICK J. RUBEY & COMPANY, LTD. CERTIFIED PUBLIC ACCOUNTANTS American Taxpayer Relief Act January 1, 2013 Here are the act s main tax features: Individual tax rates All the individual marginal tax rates
More informationSPECIAL TAX NOTICE REGARDING PLAN PAYMENTS
SPECIAL TAX NOTICE REGARDING PLAN PAYMENTS This notice explains how you can continue to defer federal income tax on your retirement plan savings in the Plan and contains important information you will
More informationWashington Report 13-16
Washington Report 13-16 Washington Report 13-16 2014 Budget Renews Old Proposals and Reveals a Few Surprises. MARKET TREND: The Administration continues to focus on the taxation of high income taxpayers
More informationFiscal Year (FY) 2015 Budget Proposals
March 2014 taxalerts.plantemoran.com Fiscal Year (FY) 2015 Budget Proposals Obama Emphasizes Individuals, Targets Business Tax Incentives In FY 2015 Budget President Obama renewed his call for expanding
More informationMay 20, 2009 Client Alert
Client Alert Bei j i n g Fr a n k f u r t Ho n g Ko n g Lo n d o n Lo s An g e l e s Mu n i c h Ne w Yo r k Si n g a p o r e To k y o Wa s h i n g t o n, DC International Tax Regime Targeted in Latest
More informationWeb: www.aldavlaw.com Blog: www.californiatrustestateandprobatelitigation.com GIFTS TO MINORS
Web: www.aldavlaw.com Blog: www.californiatrustestateandprobatelitigation.com GIFTS TO MINORS Grandparents and other relatives and friends often desire to make lifetime gifts to or for the benefit of a
More information10 common IRA mistakes
10 common mistakes Help protect your valuable retirement assets Not FDIC Insured May Lose Value No Bank Guarantee Not Insured by Any Government Agency You ve worked hard to build your retirement assets......
More informationMinimum Distributions & Beneficiary Designations: Planning Opportunities
28 $ $ $ RETIREMENT PLANS The rules regarding distributions and designated beneficiaries are complex, but there are strategies that will help minimize income and estate taxes. Minimum Distributions & Beneficiary
More informationLIFE INSURANCE TRUSTS
LIFE INSURANCE TRUSTS Robert M. Mendell, JD, CPA* Robert M. Mendell, Attorney at Law, P.C. 908 Town & Country Blvd. Suite 120 Houston, Texas 77024 (713) 888-0700 Fax: (713) 888-0800 Email: rmendell@mendellgroup.com
More informationchart retirement plans 8 Retirement plans available to self-employed individuals include:
retirement plans Contributing to retirement plans can provide you with financial security as well as reducing and/or deferring your taxes. However, there are complex rules that govern the type of plans
More informationOf the. Are there any other cities in New York State that impose an income tax?
New York Tax Report 2015 Edition New York Personal Income Tax Although managing your portfolio is primarily an investment decision, tax considerations should also be taken into account. Accordingly, Morgan
More informationThe Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010
Advisory Estates, Trusts & Tax Planning Tax March 3, 2011 New Estate and Gift Tax Laws for 2011-2012 and Transfer Tax Provisions of the President's Proposed Budget for 2012 by Jennifer Jordan McCall, Ellen
More informationOVERVIEW OF THE FEDERAL TAX SYSTEM AS IN EFFECT FOR 2012
OVERVIEW OF THE FEDERAL TAX SYSTEM AS IN EFFECT FOR 2012 Prepared by the Staff of the JOINT COMMITTEE ON TAXATION February 24, 2012 JCX-18-12 CONTENTS Page INTRODUCTION... 1 I. SUMMARY OF PRESENT-LAW FEDERAL
More informationtax bulletin State of Play: International Tax Policy in the 111 th Congress www.venable.com AUGUST 2010 By E. Ray Beeman and Samuel Olchyk
tax bulletin www.venable.com AUGUST 2010 State of Play: International Tax Policy in the 111 th Congress By E. Ray Beeman and Samuel Olchyk The 111th Congress will soon return from its summer recess to
More informationFInancIal PlannIng In an uncertain tax landscape. understanding today s tax environment // strategies for 2012 // Planning for 2013
FInancIal PlannIng In an uncertain tax landscape understanding today s tax environment // strategies for 2012 // Planning for 2013 Key Takeaways Without further changes by Congress, tax rates are scheduled
More informationPartner s Instructions for Schedule K-1 (Form 1065) Partner s Share of Income, Deductions, Credits, etc. (For Partner s Use Only)
2009 Partner s Instructions for Schedule K-1 (Form 1065) Partner s Share of Income, Deductions, Credits, etc. (For Partner s Use Only) Department of the Treasury Internal Revenue Service Section references
More informationbusiness owner issues and depreciation deductions
business owner issues and depreciation deductions Individuals who are owners of a business, whether as sole proprietors or through a partnership, limited liability company or S corporation, have specific
More informationPartner's Instructions for Schedule K-1 (Form 1065-B)
2015 Partner's Instructions for Schedule K-1 (Form 1065-B) Partner's Share of Income (Loss) From an Electing Large Partnership (For Partner's Use Only) Department of the Treasury Internal Revenue Service
More informationTRADITIONAL AND ROTH IRA SUMMARY & AGREEMENT
TRADITIONAL AND ROTH IRA SUMMARY & AGREEMENT SEPTEMBER 2004 T. Rowe Price Privacy Policy In the course of doing business with T. Rowe Price, you share personal and financial information with us. We treat
More informationLIFE INSURANCE DIVISION
TAX LAW SUMMARY American Taxpayer Relief Act MKTG-OC-1053A LIFE INSURANCE DIVISION TAX LAW SUMMARY American Taxpayer Relief Act INDIVIDUAL TAX PROVISIONS...3 Individual Tax Rates...3 Marriage Penalty Relief...4
More informationTAX CONSEQUENCES FOR U.S. CITIZENS AND OTHER U.S. PERSONS LIVING IN CANADA
March 2015 CONTENTS U.S. income tax filing requirements Non-filers U.S. foreign reporting requirements Foreign trusts Foreign corporations Foreign partnerships U.S. Social Security U.S. estate tax U.S.
More informationGeneral Explanations of the Administration s Fiscal Year 2015 Revenue Proposals
General Explanations of the Administration s Fiscal Year 215 Revenue s Department of the Treasury March 214 General Explanations of the Administration s Fiscal Year 215 Revenue s Department of the Treasury
More informationROTH IRA DISCLOSURE STATEMENT
Toll Free: 1-800-962-4238 www.pensco.com ROTH IRA DISCLOSURE STATEMENT This Disclosure Statement summarizes the requirements for the Roth Individual Retirement Account (Roth IRA). The rules under which
More informationIRA Custodian Disclosure Statement and Plan Agreement
Deutsche Asset & Wealth Management IRA Custodian Disclosure Statement and Plan Agreement Retain these pages for your records. Custodian disclosure statement The following information is provided to you
More informationTHE TAX-FREE SAVINGS ACCOUNT
THE TAX-FREE SAVINGS ACCOUNT The 2008 federal budget introduced the Tax-Free Savings Account (TFSA) for individuals beginning in 2009. The TFSA allows you to set money aside without paying tax on the income
More information