Tobacco Buyout Issues: Inherited or Gifted Tobacco Quota Buyout Installment Contracts
|
|
- Chester Howard
- 8 years ago
- Views:
Transcription
1 Tobacco Buyout Issues: Inherited or Gifted Tobacco Quota Buyout Installment Contracts Guido van der Hoeven Agriculture Extension Specialist North Carolina State University T. Michael Till Extension Assistant i
2 INHERITED OR GIFTED TOBACCO CONTRACT Tobacco quota installment payments will continue through 2014, and recipients reside in all 50 states as well as foreign countries. Some of the original recipients have died or given away their installment contracts. This issue looks at the tax treatment of an inherited or gifted tobacco transition payment contract. Background The American Jobs Creation Act of 2004 (Pub. L. No ) included the Fair and Equitable Tobacco Reform Act of 2004 (Tobacco Reform Act), which created the Tobacco Transition Payment Program (TTPP), often called the tobacco quota buyout. Taxpayers who owned tobacco quota and/or grew tobacco under the quota system are receiving installment payments unless they sold the installment contract for a lump sum. The first installment payment was made in the fall of 2005; subsequent annual installment payments are received in January each year, with the tenth and final payment to be made in The tobacco buyout includes two types of payments, plus, for some taxpayers, unstated interest. The first payment buys out the quota, which generally is a business asset (I.R.C. 1231; Notice , C.B. 74; and Notice , C.B. 267). Consequently, gain or loss from the sale of the quota is I.R.C gain or loss, which is netted with other I.R.C gains or losses for the year. A net gain is treated as a capital gain and a net loss is treated as an ordinary loss. The second payment replaces lost tobacco income for producers of tobacco. It is generally ordinary income subject to SE tax. Production localities of tobacco are listed below; however, tobacco quota installment recipients reside in all fifty states and many foreign countries, therefore, the tax consequences reach far beyond the locations listed. Types of tobacco grown are also listed. Flue-cured (types 11-14); Flue-cured tobacco is grown in Alabama, Florida, Georgia, North Carolina, South Carolina and Virginia. Burley (type 31): Burley tobacco is grown in Alabama, Arkansas, Georgia, Indiana, Kansas, Kentucky, Missouri, North Carolina, Ohio, Oklahoma, Tennessee, Virginia and West Virginia. Fire-cured (types 21-23): Fire-cured tobacco is grown in Kentucky, Tennessee, and Virginia. Dark air-cured (types 35 and 36); Dark air-cured tobacco is grown in Indiana, Kentucky and Tennessee. Virginia sun-cured (type 37): Virginia sun cured-tobacco is grown exclusively in Virginia. Cigar filler/binder (types and 54 and 55); cigar filler/binder is grown exclusively in Wisconsin. 1
3 Taxpayers and the tax professionals who prepare tax returns that include TTPP installment income must reconcile the installment payment into the distinct parts of that payment: tobacco quota basis recovery, tobacco quota buyout gain (or loss), and unstated interest, if any. Some taxpayers also receive a grower payment (commonly called $3 money), and this income is treated separately from the buyout payment ($7 per pound). Taxpayers and tax professionals are beginning to encounter issues regarding the reporting of tobacco buyout installment payments when the original recipient dies or makes a gift of the TTPP installment contract. This discussion clarifies the tax issues that must be addressed when dealing with an inherited or gifted TTPP installment contract. Reporting by Original Recipient Understanding the original recipient s reporting of a TTPP contract provides a foundation for identifying and understanding the tax issues involved with contracts owned by a decedent s estate, a beneficiary, or a donee. Example 1. TTPP Reporting in 2005 Golden Leif is a former tobacco quota owner. Figure 1 shows the information reported on the Form 1099-S, Proceeds from Real Estate Transactions, that he received in 2005, plus other information that is needed to report the buyout of Golden s tobacco quota. FIGURE 1: GOLDEN S TOBACCO BUYOUT INFORMATION Item Information Source Closing date 7/08/2005 Box 1 of Form 1099-S Gross proceeds $85,449 Box 2 of Form 1099-S Date acquired 6/15/1994 Golden s records Basis of quota $20,000 Golden s records Amortization claimed None Golden s records Figure 2 shows the summary of unstated interest that was provided by the USDA with Form 1099-S, and the portion of each payment that is allocated to principal. FIGURE 2: SUMMARY OF UNSTATED INTEREST Year Unstated Interest Principal Total Payment 2005 $ 0.00 $8, $8, , , , , , , , , , , , , , , , , , , , , , , , Total $11, $73, $85,
4 Golden did not elect out of installment reporting. In 2005, his tax preparer calculated his gross profit and reported it on Form 6252, Installment Sale Income, as shown in Figure 3. FIGURE 3: GOLDEN S 2005 FORM 6252 The 2006 and 2007 installment payments were also reported on Form For each year, the taxable portion of the principal payment was carried to Form 4797, Sales of Business Property, and then to Schedule D (Form 1040), Capital Gains and Losses. There was no unstated interest for 2006, as shown in Figure 2, so the entire $8, installment payment was reported on line 21 of Form For 2007, the $5, principal reported on line 21 of Form 6252 is the $8, installment payment reduced by the $3, unstated interest. 3
5 Unstated Interest The Tobacco Reform Act does not state any interest for the TTPP payments, but I.R.C. 483 and 1274 require unstated interest to be calculated and reported. I.R.C. 483 applies to installment sales for at least $3,000 but not more than $250,000. I.R.C applies to installment sales for more than $250,000; this interest is treated as original issue discount (OID). TTPP recipients received either a Form 1099-INT, Interest Income, or a Form 1099-OID, Original Issue Discount, in 2007 and they will also receive one of those forms in each subsequent year. The unstated interest reported for each year should match the amount found on the Form 1099-S supporting table, as illustrated in Figure 2 for Golden Leif. Example 2. TTPP Reporting in 2007 and Later Years Golden Leif received his third $8, TTPP installment payment on January 15, Because his contract amount is less than $250,000, the I.R.C. 483 unstated interest rules apply, and he received a Form 1099-INT reporting $3, of interest in box 1, which matches the table he received in 2005 (See Figure 2). Golden reported the unstated interest on his 2007 Schedule B (Form 1040), as shown in Figure 4. FIGURE 4: GOLDEN S 2007 SCHEDULE B (FORM 1040) Golden reported only the $5, principal portion of the 2007 TTPP installment payment on his 2007 Form 6252, as shown in Figure 5. Observation Common Error A frequent error is failing to subtract the unstated interest from the total payment before reporting the principal amount on Form 6252, because the taxpayer does not receive an annual Form 1099-S showing the principal amount of the payment for that year. 4
6 FIGURE 5: GOLDEN S 2007 FORM 6252 Golden continues to report his TTPP installment payments in this manner until the end of the contract in Figure 6 summarizes the 2005, 2006, and 2007 reporting of Golden s TTPP installment payments. FIGURE 6: SUMMARY OF GOLDEN S TTPP INSTALLMENT PAYMENTS Year Payment Received Unstated Interest Principal Basis Recovered Gain Reported 2005 $8, $0.00 $8, $2, $6, , , , , , , , , , Totals $25, $3, $22, $6, $ Example 3. Reporting Grower Payment in 2007 Golden Leif also receives grower installment payments. His average production was 12,207 pounds for the years used to calculate the grower portion of the TTPP payments. Because he continues to actively and materially participate in his farming business, Golden reports the annual grower payment on Schedule F (Form 1040). Golden s grower payments will total $36,621 (12,207 lbs. $3/lb.) over the 10-year period, so his annual payment is $3, Golden reports this income on line 6a and 6b of his Schedule F (Form 1040), as shown in Figure 7, and it becomes part of his net earnings from self-employment. 5
7 FIGURE 7: GOLDEN S 2007 SCHEDULE F (FORM 1040) Retired or Disabled Taxpayers The IRS has not released any guidance about reporting of the TTPP grower payments. It is unclear whether these payments are subject to SE tax for retired or disabled recipients. Consequently, if a recipient of grower payments is retired or disabled, there are two alternatives to using Schedule F (Form 1040) for reporting this income. One is to use lines 3a and 3b of Form 4835, Farm Rental Income and Expenses. The second alternative is to report this income as other income on line 21 of Form The grower payments are clearly ordinary income, because they are a replacement for tobacco sales. The recently pass 2008 Farm Bill includes a provision excluding CRP payments from self-employment taxation for individuals who are retired or who are permanently disabled (receiving Social Security Payments). Practitioners may be able to stake out a position using the new Farm Bill. Inheriting a TTPP Contract When a taxpayer who owns a TTPP installment contract dies, the contract becomes an asset of the decedent s estate. A technical correction to the initial legislation allows a subsequent transfer of ownership. Successor in Interest The TTPP contract is an agreement entered into by the USDA and a taxpayer who formerly owned a tobacco quota. Once the contract is accepted and formalized by both parties, only the taxpayer is entitled to receive the installment payments. If the taxpayer dies, the original legislation allowed only a surviving spouse to receive the payments. If there was no surviving spouse, the estate was to remain open until the contract period ended. Fortunately, a technical 6
8 correction to the original legislation allows the payments to be made to beneficiaries other than a spouse. If the taxpayer dies after receiving the current year s installment payment (the payment for the year of death) and he or she directed the disposition of the TTPP contract in a will or other document, the executor of the decedent s estate should use USDA Form CCC-968, Tobacco Transition Payment Program Master Successor-in-Interest Contract, to transfer the payments to the successor. USDA Form CCC-968 An electronic copy of USDA Form CCC-968 can be obtained from the following Web site: Example 4. Successor in Interest of TTPP Contract On March 15, 2007, Golden Leif died without a surviving spouse. His son, Dark Leif, inherited the TTPP contract. As executor of Golden s estate, Dark used Form CCC-968 to notify the USDA that he is the successor in interest of Golden s tobacco installment contract. Income in Respect of Decedent Installment contract payments that are unpaid at the time of death of a decedent are income in respect of a decedent (IRD) to the estate or other recipient of the contract [I.R.C. 453B(c)]. The total IRD is the excess of the face amount of the remaining installment obligation over the decedent s basis in the contract at the time of death [I.R.C 453B(b) and 691(a)(4)]. The remaining gain on the contract is not generally reported on the decedent s final income tax return [I.R.C. 691(a)(4)]. Instead, the IRD is reported by the recipient of the payments as the remaining payments are made. Cancellation at Death An exception applies if the remaining payments on an installment contract are canceled on the death of the contract holder, or if the buyer of the installment contract inherits the remaining payments. When this occurs, the payments are treated as being made in full to the estate in the year of death, and the estate must report the gain on its income tax return. Installment payments received by a decedent s estate or other beneficiary are included in gross income in the same way the decedent would have reported them [Treas. Reg (a)- 5(a)]. In other words, an installment contract does not receive a basis adjustment to FMV upon the death of the contract holder. Therefore, a TTPP installment contract has continuing income tax consequences for the estate or the beneficiaries who inherit it. The character of the IRD for the estate or beneficiaries is the same as it was for the decedent [I.R.C. 691(a)(3); Treas. Reg (a)-3(a)]. The IRD is reported for the tax year it is received by 1. The decedent s estate, if the estate acquires the right to receive the TTPP payments 2. The person who obtains the right to the TTPP payments when the right passes outside of the decedent s estate 7
9 3. The person who obtains the right by bequest, devise, or inheritance if the TTPP payments are received after the decedent s estate distributes that right to receive the income Example 5. Estate Reporting of TTPP Income Golden Leif, from Example 4, received his January 2007 TTPP installment payment before he died on March 15, 2007, so that 2007 installment payment was reported on his final income tax return as illustrated in Figure 5. Because the estate did not distribute any assets before the January 2008 payment was received, Golden s executor, Dark Leif, reports the January 2008 TTPP installment on a 2008 Form 6252 filed with the estate s Form 1041, U,S. Income Tax Return for Estates and Trusts. The Form 6252 result flows to Schedule D (Form 1041) and then to line 4 of Form 1041 as shown in Figures 8, 9, and 10. The $1, of unstated interest shown in Figure 2 for 2008 is reported on line 1 of Form As in Example 3, the grower payment is reported on Schedule F (Form 1040), but it then is entered on line 6 of Form The estate had no other income, so its total income reported on line 9 of Form 1041 is the $10, that is recognized from the 2008 TTPP payments. FIGURE 8: 2008 FORM 6252 FOR GOLDEN S ESTATE 8
10 FIGURE 9: 2008 SCHEDULE D (FORM 1041) FOR GOLDEN S ESTATE FIGURE 10: 2008 FORM 1041 FOR GOLDEN S ESTATE 9
11 Reporting on Form 1040 If Dark Leif had requested a succession in interest to himself as the sole beneficiary of Golden Leif s estate, his income tax reporting of the TTPP payments would be similar to the estate s reporting. Dark would report the following amounts on schedules attached to his 2008 Form 1040: $1, of interest on Schedule B (Form 1040) $3, of grower payments on Schedule F (Form 1040), or on line 21 of Form 1040, as discussed later in this section $4, of gain on Form 6252, carried to Schedule D (Form 1040) Sale of Inherited TTPP Contract Beneficiaries and executors who manage TTPP installment contracts may choose to cash out by selling the TTPP contract to a financial institution that is willing to buy the contract at a discount. Because the contract proceeds are IRD, the beneficiary or estate reports income or loss in the same manner as if the original owner had made the sale. The gain or loss is the difference between the contract s FMV (generally, its selling price) and the remaining basis in the contract [I.R.C. 691(a)(4); Treas. Reg (a)-5(b)]. If a beneficiary who inherits a TTPP installment contract sells the contract to a financial institution, the Form CCC-698 discussed earlier in this section is used to transfer the contract to the purchasing financial institution. Example 6. IRD from Sale of TTPP Contract The facts are the same as in Example 5, except that the estate distributed the installment contracts to Dark Leif on June 15, On November 15, 2007, Dark made a lump-sum sale of both the TTPP installment contract and the grower payment installment contract for 75% of their face value to an unrelated financial institution. He received $44, (75% of the $59, remaining balance on the TTPP contract) plus $19, (75% of the $25, remaining\ balance on the grower contract) in one lump-sum payment. Because these payments retain their character as capital gain and ordinary income, Dark must report the amounts separately on his personal tax return. He computes his basis in the TTPP contract by subtracting the $6, basis that was recovered in the first three payments (see Figure 6) from the original $20,000 basis in the contract. The result is $13, Dark reports the $44, that is allocated to the TTPP contract and its $13, basis on Form 4797, as shown in Figure 11, and carries the $30, gain to line of Schedule D (Form 1040) as shown in Figure 12. He reports the $19, payment for the grower contract as other income on line 21 of Form
12 FIGURE 11: 2007 FORM 4797 FOR DARK LEIF Contract Retains I.R.C Character Gain from the sale of a TTPP installment contract is I.R.C gain, because the underlying asset (the tobacco quota) was an I.R.C asset [Treas. Reg (d)]. Also, assets that are inherited are deemed to be long-term assets in the hands of the beneficiary [I.R.C (9)(B)]. 11
13 FIGURE 12: 2007 SCHEDULE D (FORM 1040) FOR DARK LEIF Observation Form 1040 Line 22 If Dark Leif, in the above example, was not a farmer, a plausible argument might be made to report the Grower Payment on line 22, Other Income, Form The IRS has not issued guidance relative to the Grower Payments under TTPP. Inherited Grower Contract Although the grower TTPP contract payments are subject to SE tax when they are received by the grower, they are arguably not subject to SE tax when they are received by a beneficiary. The beneficiary was not involved in the production of tobacco in the years 2002, 2003, and 2004, upon which the grower payments are based. In Rev. Rul , C.B. 224, a surviving spouse received commissions on life insurance policies that her husband sold before his death. The commissions received by her husband before his death were SE income because he was a self-employed agent, but the commissions she received after his death were not SE income for her because they were not derived from a trade or business that she carried on. In the case of grower TTPP contracts, the beneficiary can argue that the payments are not derived from a trade or business carried on by the beneficiary. That argument can be made by a beneficiary even if he or she is an active farmer, because the payments are not derived from the beneficiary s trade or business. Based on this argument, the beneficiary who inherits a grower contract reports the installment payments on line 21, Other income, of Form Deduction of Estate Tax The value of the right to receive IRD is included in the decedent s gross estate for assessment of the estate and generation-skipping transfer taxes. Nevertheless, when beneficiaries receive the income, they must report and recognize the IRD on their individual tax returns. The Internal Revenue Code provides a measure of relief from potential double taxation (although it is not an efficient measure of relief). 12
14 When a beneficiary reports IRD income on his or her current year s tax return, the beneficiary can deduct an allocable portion of the estate or generation-skipping transfer tax paid by the estate. The deduction is taken on Schedule A (Form 1040) as a miscellaneous itemized deduction that is not subject to the 2%-of-AGI floor. The allowable deduction is calculated by prorating the estate tax or generation-skipping tax to the IRD income included in the gross estate [I.R.C. 67(b)(8)]. Gifting a TTPP Contract Giving an installment contract to another taxpayer can have both gift and income tax consequences for the donor. Gift Tax Consequences Gifts are complete when the donor relinquishes any and all rights, claims, or control over the property [Treas. Reg (b)]. Gifts include transfers of present and future interests in property [I.R.C. 2503(b)(1) and Treas. Reg ], but gifts of future interests do not qualify for the annual gift tax exclusion ($12,000 in 2008) [I.R.C. 2503(b)(1)]. Treasury regulations define a present interest in property as an unrestricted right to the immediate use, possession, or enjoyment of property or the income from property (Treas. Reg ). A gift of a TTPP installment contract is a gift of present interest because the done could sell the contract for a lump-sum payment to a financial institution. Gift Tax Nature Gift tax is imposed on the transfer of property, not on the transferred property itself [I.R.C (a)]. Value of a TTPP Contract For purposes of both income taxes and gift taxes, the value of a TTPP installment contract is the present value of the future payments [Treas. Reg (a)(1) and (a)]. The present value of the future payments is calculated by multiplying the aggregate amount payable annually by the appropriate actuarial factor that corresponds to the applicable I.R.C interest rate and annuity period. The applicable I.R.C interest rate is 120% percent of the mid-term applicable federal rate (AFR) in effect under I.R.C. 1274(d)(1) for the month in which the valuation date falls. The rate is rounded to the nearest two-tenths of 1%. Actuarial factors for an annuity payable for a term certain for valuation dates after April 30, 1999, are published in IRS Publication 1457, Actuarial Values Book Aleph, Table B [Treas. Reg (d)(2)(iv)(A)]. Market for TTPP Installment Contracts There is a thin market for TTPP installment contracts, which could be used to determine the FMV of the contracts. However, the IRS is likely to require using the I.R.C factor to value a gift of the right to receive the remaining payments on a TTPP installment contract. 13
15 Example 7. Value of TTPP Contract Golden Leif, from the previous examples, gave his TTPP installment contract to his son Dark Leif immediately after Golden received his fourth installment payment in January For both income and gift tax purposes, the amount of the gift is the present value of the six remaining $8, annual payments. Golden s basis in the contract is $12,172. That is his $20,000 basis in the tobacco quota reduced by the basis he recovered to offset gain on the first four installment payments. Figure 6 shows the $6, basis recovered on the first three installment payments. The basis he recovered on the fourth (2008) payment is $1, the $6, principal payment shown in Figure 2 reduced by the $4, gain ($6, gross profit ratio). Golden computes the present value of the payments by first finding the I.R.C interest rate for January 2008, which is 4.4% [Rev. Rul , I.R.B. 272, Table B]. The actuarial factor for a 6-year term-certain annuity at a 4.4% interest rate is then located in Table B of IRS Publication This factor is Finally, Golden multiplies the $8, amount of the annual payments by the actuarial factor to find the $44,216 value of the TTPP installment contract. As shown in Figure 13, Golden reports the $44,216 gift on line 1, Part 1, Schedule A, of Form 709, United States Gift (and Generation-Skipping Transfer) Tax Return. The $12,000 annual exclusion is deducted on line 2, Part 4, Schedule A, of Form 709, reducing the taxable gift to $32,216, which is reported on line 1, Part 2, of Form 709. Golden does not pay any gift tax because his total taxable gifts since 1976 are less than the $1,000,000 applicable exclusion amount. 14
16 FIGURE 13: GOLDEN S 2008 FORM
17 Donee s Liability for Gift Tax The federal gift tax is imposed on the donor [I.R.C. 2502(c)]. However, if the gift tax is not paid when due, I.R.C. 6324(b) imposes the tax on the donee and creates a lien on the property that was given to the donee. State Gift Taxes Some states impose a gift tax that may be more significant than the federal gift tax. Income Tax Issues for Donor Gifting a TTPP installment contract can create an income tax pitfall for the donor, because the gift is treated as a disposition of the installment obligation [I.R.C. 453B(a) and Rev. Rul , C.B. 294]. The donor realizes and recognizes gain (or loss) equal to the difference between the contract s FMV and its remaining basis [I.R.C. 453B(a) and (b)]. The contract s FMV for income tax purposes is calculated in the same manner as the gift tax value [Treas. Reg (a)(1)]. Example 8. Gain on Gift of TTPP Contract Because Golden gave the TTPP contract to his son, Dark Leif, he must recognize gain as if he had received the contract s FMV in cash at the time of the gift. Using the facts in Example 7, the contract s FMV is $44,216 and his remaining adjusted basis is $12,172. Golden must report the $32,044 gain on his 2008 Form 4797, Schedule D (Form 1040), and Form 1040 as if he had sold the TTPP installment contract for $44,216 just as the sale of the contract was reported in Example 6. Double Taxation In giving the this gift of the installment payment, Golden is seemingly subject to double taxation, gift tax and income tax on the same transation. 16
18 Income Tax Issues for Donee The TTPP contract is not an installment contract in the hands of the donee, because the donor was required to recognize the gain on the contract. The contract becomes an annuity contract in the hands of the donee. I.R.C. 72 requires annuity payments to be included in the donee s income to the extent they exceed the exclusion ratio. To calculate that ratio, the donee s basis in the contract must be determined. Donee s Basis in TTPP Contract The donee s basis in the contract is the donor s basis [I.R.C. 1015(a)], increased by any gift tax paid that is attributable to the appreciation [I.R.C. 1015(d)]. Because the gift triggers recognition of gain by the donor, that gain is added to the donor s basis before it is transferred to the donee [I.R.C. 1015(a) and Rev. Rul , supra]. If the basis (adjusted for any gift tax paid) is less than the face value of the remaining payments, the difference is treated as original issue discount (OID). Generally OID is treated and reported as interest on Schedule B Form Exceptions to OID Rules There are exceptions to the OID rules for nonpublicly traded debt instruments such as TTPP installment contracts. These exceptions are found in I.R.C and supporting Treasury Regulations The rules are complicated. Example 9. Basis of Gifted TTPP Contract In Example 8, Dark Leif received the TTPP contract as a gift from his father, Golden Leif. Dark s basis is $44,216 (the sum of Golden s $12,172 basis and the $32,044 gain Golden recognized on the deemed disposition). Donee s Income from Contract Payments I.R.C. 72(b) allows the donee to exclude a portion of each payment from income. The amount excluded is the part of the payment that bears the same ratio to the annual payment as the basis in the contract bears to the expected total payments [Treas. Reg (c)]. Example 10. Payments Received by Donee Dark Leif will receive six annual payments of $8,544.90, for a total of $51, He reports the $8, annual payment on line 16a of Form 1040, excludes $7, [($44,216 $51,269) $8,544.90] of each payment, and reports the remaining $1, taxable amount as ordinary income on line 16b of Form Subsequent Sale of Contract If the donee sells the TTPP contract, he or she must recognize the difference between the basis in the contract at the time of the sale and the amount realized on the sale as gain or loss. The gain or loss from the sale of a right to receive future ordinary income is ordinary gain or loss [Commissioner v. P.G. Lake, Inc., 356 U.S. 260 (1958)]. 17
19 Planning Pointer Avoid Gifts of TTPP Contract Instead of giving the TTPP contract to the donee, it is better to give the payments from the contract to the donee each year as they are received. That avoids accelerating the reporting of gain on the TTPP installment contract. 18
If the owner-annuitant of a deferred annuity contract dies before the annuity
Part I Section 691. Recipients of Income in Respect of Decedents 26 CFR 1.691(a)-1: Income in respect of a decedent. (Also 72, 1014.) Rev. Rul. 2005-30 ISSUE If the owner-annuitant of a deferred annuity
More informationHow To Tax An Annuity In The United States
Thursday, December 18 2014 WRM# 14-49 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 informationPRIVATE ANNUITIES A VERSATILE
AMERICAN COLLEGE OF TRUST AND ESTATE COUNSEL NOVEMBER 10, 2002 PRIVATE ANNUITIES A VERSATILE ESTATE PLANNING TOOL PRESENTED BY: STEPHEN H. GARIEPY Stephen H. Gariepy Hahn Loeser + Parks, LLP 3300 BP Tower,
More informationOPTIONAL BASIS ADJUSTMENTS
I. INTRODUCTION OPTIONAL BASIS ADJUSTMENTS As a general rule, a partnership s basis in property is its cost, or in the case of contributed property, the property s adjusted basis in the hands of the contributing
More informationROLLOVERS FROM QUALIFIED RETIREMENT PLANS AND IRAS: A PRIMER
ROLLOVERS FROM QUALIFIED RETIREMENT PLANS AND IRAS: A PRIMER Louis A. Mezzullo Luce, Forward, Hamilton & Scripps LLP Rancho Santa Fe, CA lmezzullo@luce.com (October 21, 2011) TABLE OF CONTENTS Page I.
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 informationPROBLEM SOLVING WITH GIFT ANNUITIES (Part 1)
PROBLEM SOLVING WITH GIFT ANNUITIES (Part 1) VOL. IV, NO. 1-1996 by David Wheeler Newman Creative charitable gift planning often focuses on charitable remainder trusts and charitable lead trusts while
More informationPreparing a Federal Estate Tax Return Form 706, By Yahne Miorini, LL.M.
You must attach to the return a certified copy There are 5 parts in the Form 706, 9 schedules to determine the gross estate, and 7 schedules for deductions. It is a good practice to include all of the
More informationA Dangerous Tax Trap in Structured Settlements
THE LAW FIRM OF BOVE & LANGA A PROFESSIONAL CORPORATION TEN TREMONT STREET, SUITE 600 BOSTON, MASSACHUSETTS 02108 Telephone: 617.720.6040 Facsimile: 617.720.1919 www.bovelanga.com A Dangerous Tax Trap
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 informationTHE AMERICAN LAW INSTITUTE Continuing Legal Education. Estate Planning in Depth
711 THE AMERICAN LAW INSTITUTE Continuing Legal Education Estate Planning in Depth Cosponsored by Continuing Legal Education for Wisconsin (CLEW) June 21-26, 2015 Madison, Wisconsin Tentative Thoughts
More informationYour U.S. vacation property could be quite taxing by Jamie Golombek
June 2015 Your U.S. vacation property could be quite taxing by Jamie Golombek It seems everywhere we look, Canadians are snapping up U.S. vacation properties. Though your vacation property may be located
More information26 CFR 601.201: Rulings and determination letters. (Also: Part I, 170, 642(c), 2055, 2522; 1.170A-6, 20.2055-2, 25.2522(c)-3)
Part III Administrative, Procedural, and Miscellaneous 26 CFR 601.201: Rulings and determination letters. (Also: Part I, 170, 642(c), 2055, 2522; 1.170A-6, 20.2055-2, 25.2522(c)-3) Rev. Proc. 2007-45 SECTION
More informationSplit-Interest Charitable Giving Techniques in brief
Split-Interest Charitable Giving Techniques in brief Summary of Split-Interest Charitable Giving Techniques Charitable Remainder Trust Allows the donor to provide a gift to charity (i.e., the remainder
More informationCHAPTER 6 Estate Tax
CHAPTER 6 Estate Tax DISCUSSION QUESTIONS 1. List six assets included in a decedent s gross estate. 1. Cash. 2. Stocks and bonds. 3. Annuities. 4. Retirement accounts. 5. Notes receivable. 6. Residences.
More informationISSUES TO CONSIDER IN STRUCTURING A PARTNER BUY-OUT: SALE VERSUS REDEMPTION
ISSUES TO CONSIDER IN STRUCTURING A PARTNER BUY-OUT: SALE VERSUS REDEMPTION ABC LLC is owned equally by individuals A, B, and C. C wishes to retire from the partnership. Should he sell his interest equally
More informationCHAPTER 8 TAX CONSIDERATIONS
CHAPTER 8 TAX CONSIDERATIONS Life insurance traditionally has enjoyed favorable tax treatment. The major advantages are (1) the death benefits of a life policy payable to a beneficiary are not subject
More informationPLANNING FOR INDIVIDUALS WITH DIMINISHED LIFE EXPECTANCY ERIC REIS
PLANNING FOR INDIVIDUALS WITH DIMINISHED LIFE EXPECTANCY ERIC REIS Thompson & Knight, LLP 1722 Routh Street, Suite 1500 Dallas, Texas 75201 Phone: (214) 969-1118 Email: eric.reis@tklaw.com North Texas
More informationThursday, 3 December 2015 WRM# 15-44
Thursday, 3 December 2015 WRM# 15-44 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 informationIrrevocable Life Insurance Trusts: Perhaps the Best Kept Secret in Tax Savings
Irrevocable Life Insurance Trusts: Perhaps the Best Kept Secret in Tax Savings A. Jude Avelino * Life insurance is protection against the death of an individual in the form of payment to a beneficiary,
More informationU.S. Taxes for Canadians with U.S. assets
U.S. Taxes for Canadians with U.S. assets December 2014 U.S. Gift, Estate and Generation Skipping Transfer Tax can affect Canadians who don t even live in the United States. This article examines how these
More informationTHE TOP TEN INSURANCE PLANNING MISTAKES IN AN ESTATE PLANNING CONTEXT
THE TOP TEN INSURANCE PLANNING MISTAKES IN AN ESTATE PLANNING CONTEXT LAWRENCE BRODY BRYAN CAVE LLP Copyright 2011. Lawrence Brody. All Rights Reserved. 3585078.1 THE TOP TEN INSURANCE PLANNING MISTAKES
More informationEstate Planning. Farm Credit East, ACA Stephen Makarevich
Estate Planning Farm Credit East, ACA Stephen Makarevich Farm Business Consultant 9 County Road 618 Lebanon, NJ 08833 1.800.787.3276 stephen.makarevich@farmcrediteast.com 1 What is Estate Planning? 2 Estate
More informationNonqualified annuities can be classified in a number of ways:
The term annuity refers to any situation where principal and interest are paid out in a series of regular payments. A nonqualified annuity, generally, is an annuity purchased by an individual from a life
More informationForm CT-706 NT Instructions Connecticut Estate Tax Return (for Nontaxable Estates)
(Rev. 06/11) Form CT-706 NT Instructions Connecticut Estate Tax Return (for Nontaxable Estates) General Information For decedents dying on or after January 1, 2011, the Connecticut estate tax exemption
More informationTreacherous Waters: Using IRD for Charitable Bequests. A Charitable Income Tax Deduction For A Bequest Of IRD?
Treacherous Waters: Using IRD for Charitable Bequests Christopher R. Hoyt Professor of Law University of Missouri (Kansas City) School of Law (c) 2008 Christopher R. Hoyt All Rights Reserved In IRS Chief
More informationPARTNERSHIP INTERESTS IN ESTATE AND TRUST ADMINISTRATION
PARTNERSHIP INTERESTS IN ESTATE AND TRUST ADMINISTRATION by Gary A. Zwick Working with partnership interests owned by decedents either outright or in their revocable living trusts at the time of death
More informationCH.15 Non-Donative Transfers
CH.15 Non-Donative Transfers 1) Intrafamily installment sales 2) Gift-leaseback arrangements 3) Tax-free exchanges 4) Private annuities 5) Grantor retained annuity trusts 6) QPRTs 7) Joint or split purchases
More informationThe owner is usually the purchaser of the policy. However, the owner may also acquire the policy by gift, sale, exchange, or bequest.
Annuity Ownership Considerations What is an annuity owner? What are the owner's rights? Who should be the owner? What if the owner dies? Is the annuity includable in the owner's estate? What risks does
More informationOpportunities and Pitfalls Under Sections 351 and 721
College of William & Mary Law School William & Mary Law School Scholarship Repository William & Mary Annual Tax Conference Conferences, Events, and Lectures 2007 Opportunities and Pitfalls Under Sections
More informationState Tax of Social Security Income. State Tax of Pension Income. State
State Taxation of Retirement Income The following chart shows generally which states tax retirement income, including and pension States shaded indicate they do not tax these forms of retirement State
More informationHow To Get A Private Annuity
White Paper Estate Freeze Technique: Private Annuity www.selectportfolio.com Toll Free 800.445.9822 Tel 949.975.7900 Fax 949.900.8181 Securities offered through Securities Equity Group Member FINRA, SIPC,
More informationInstructions for Form 8582 Passive Activity Loss Limitations
2007 Instructions for Form 8582 Passive Activity Loss Limitations Department of the Treasury Internal Revenue Service Section references are to the Internal rental passive activities. Overall loss is limited,
More informationA New Use for Your. a donor s guide. The Stelter Company
A New Use for Your R E T I R E M E N T P L A N A S S E T S a donor s guide The Stelter Company APPRECIATED PROPERTY Learn how to uncover the value of your appreciated assets. Like many Americans, you are
More informationNotice 97-34, 1997-1 CB 422, 6/02/1997, IRC Sec(s). 6048
Notice 97-34, 1997-1 CB 422, 6/02/1997, IRC Sec(s). 6048 Returns of foreign trusts foreign gift reporting requirements tax This notice provides guidance regarding the new foreign trust and foreign gift
More informationForm CT-706 NT Instructions Connecticut Estate Tax Return (for Nontaxable Estates)
(Rev. 05/14) Form CT-706 NT Instructions Connecticut Estate Tax Return (for Nontaxable Estates) General Information For decedents dying during 2014, the Connecticut estate tax exemption amount is $2 million.
More informationHow are trusts and estates taxed for income tax purposes?
Income Taxation of Trusts and Estates How are trusts and estates taxed for income tax purposes? What are the general income tax rules for trusts? What are the general income tax rules for estates? What
More informationAnnuities. Fixed Annuity: An annuity which the amount paid out is fixed sum and is usually guaranteed.
Annuities Fixed Annuity: An annuity which the amount paid out is fixed sum and is usually guaranteed. Loads: The fees or charges paid when you purchase an annuity. Includes sales commissions. Author: Douglas
More informationCharitable Giving and Retirement Assets
Charitable Giving and Retirement Assets In this issue: Basics of IRAs Retirement Plan Basics Lifetime Taxation of Distributions from Retirement Accounts Estate Taxation of IRAs and Tax-Deferred Retirement
More informationLIFE INSURANCE PLANNING FOR CLOSELY- HELD BUSINESS
LIFE INSURANCE PLANNING FOR CLOSELY- HELD BUSINESS BY JOSHUA E. HUSBANDS PORTLAND OFFICE 2300 US BANCORP TOWER 111 SW FIFTH AVENUE PORTLAND, OREGON 97204 503-243-2300 503-241-8014 joshua.husbands@hklaw.com
More informationThe Evolution of Taxation of Split Dollar Life Insurance. by Christopher D. Scott. I. Introduction
The Evolution of Taxation of Split Dollar Life Insurance by Christopher D. Scott I. Introduction The federal government recently published final regulations and issued a revenue ruling that changes the
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 informationSeptember 11th Victim Compensation Fund Payments Are Tax- Free
September 11th Victim Compensation Fund Payments Are Tax- Free The Service has confirmed that periodic payments from the September 11th Victim Compensation Fund to victims of the terrorist attacks will
More information26 CFR 1.121-1: Exclusion of gain from sale or exchange of a principal residence. (Also: 61, 165, 691, 1001; 1.61-6, 1.165-1, 1.691(a)-1, 1.1001-1.
Section 121. Exclusion of gain from sale of principal residence 26 CFR 1.121-1: Exclusion of gain from sale or exchange of a principal residence. (Also: 61, 165, 691, 1001; 1.61-6, 1.165-1, 1.691(a)-1,
More information2012 Estate/Gift Tax Overview
Investment and Estate Planning Opportunities for High Net Worth Individuals in 2013 Presented By:, March 20, 2013 Phone: (920) 593-1701 E-mail: robert.keebler@keeblerandassociates.com Circular 230 Disclosure:
More informationbpq^qbi=dfcq=^ka=dbkbo^qflkjphfmmfkd== molsfpflkp=lc=qeb=q^u=obifbci== rkbjmilvjbkq=fkpro^k`b=^rqelofw^qflki=
bpq^qbi=dfcq=^ka=dbkbo^qflkjphfmmfkd== molsfpflkp=lc=qeb=q^u=obifbci== rkbjmilvjbkq=fkpro^k`b=^rqelofw^qflki= ^ka=gl_=`ob^qflk=^`q=lc=omnm== E qeb=q^u=obifbc=^`qòf= John H. Turner, III Phone 804.420.6480
More informationEstate Tax Concepts. for Edward and Tina Collins
Estate Tax Concepts for Edward and Tina Collins Joseph Davis, CLU, ChFC 215 Broad Street Charlotte, North Carolina 26292 Phone: 704-927-5555 Mobile Phone: 704-549-5555 Fax: 704-549-6666 Email: joseph.davis@aol.com
More informationSALES AND EXCHANGES OF PARTNERSHIP INTERESTS
SALES AND EXCHANGES OF PARTNERSHIP INTERESTS I. SECTION 741. Code 741 sets forth the basic rules with respect to the sale or exchange of a partnership interest. Section 741 treats gains and losses on sale
More informationSingle Purchase Payment
CONTRACT SUMMARY Pacific Life Insurance Company P.O. Box 2378 Omaha, NE 68103-2378 (800) 722-4448 Contract Owners (800) 722-2333 Registered Representatives www.pacificlife.com Pacific Income Provider Individual
More informationSTOCK OPTIONS & CHARITABLE GIVING: DO THEY MIX?
STOCK OPTIONS & CHARITABLE GIVING: DO THEY MIX? By Erik Dryburgh As those of us who are not in the high-tech world know all too well, the real money these days is in stock options. Perhaps I have a skewed
More informationState Individual Income Taxes: Treatment of Select Itemized Deductions, 2006
State Individual Income Taxes: Treatment of Select Itemized Deductions, 2006 State Federal Income Tax State General Sales Tax State Personal Property Tax Interest Expenses Medical Expenses Charitable Contributions
More informationGifting: A Property Transfer Tool of Estate Planning
Gifting: A Property Transfer Tool of Estate Planning by Marsha A. Goetting, Ph.D., CFP, CFCS, Professor and Extension Family Economics Specialist; and Joel Schumacher, Extension Economics Associate Economics
More informationTax Aspects of Buy-Sells
Tax Aspects of Buy-Sells By Charles A. Wry, Jr. mbbp.com Business Technology & IP Employment & Immigration Taxation 781-622-5930 Reservoir Place 1601 Trapelo Road, Suite 205 Waltham, MA 02451 781-622-5930
More informationSection 2519.--Dispositions of Certain Life Estates.
Part I Section 2519.--Dispositions of Certain Life Estates. 26 CFR 25.2519-1: Dispositions of certain life estates. (Also sections 2044; 2056; 2511; 2512; 20.2044-1; 20.2056(b)-7; 25.2511-1; 25.2512-8)
More informationSuccession Planning Case Studies
Succession Planning Case Studies Prepared by NCFC Business Consulting INTRODUCTION The following are brief descriptions of how some intergenerational business succession plans have been implemented. These
More informationWhite Paper: Using Life Insurance as an Asset in Qualified Retirement Plans
Advanced Sales White Paper: Using Life Insurance as an Asset in Qualified Retirement Plans July, 2012 Number 19-1 February 1, 2014 Contact us: AdvancedSales@voya.com Employees and business owners alike
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 information1099R BOX DESCRIPTIONS
For additional details and instructions refer to IRS 1099R Instructions 1 Gross Distribution Enter the total amount of the distribution before income tax or other deductions were withheld. This can include:
More informationFederal Estate Tax. MontGuide
Federal Estate Tax by Marsha A. Goetting, Ph.D., CFP, CFCS, Professor and Extension Family Economics Specialist; Joel Schumacher, Extension Associate Economics Specialist, Department of Agricultural Economics
More informationCharitable Remainder Annuity Trust
Key Benefits Fixed income stream payable to the donor and spouse for as long as either is alive. Income tax deduction available for the computed value of the charitable gift. Investments are managed inside
More informationThursday, May 7 2015 WRM# 15-16
Thursday, May 7 2015 WRM# 15-16 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. The WRMarketplace
More informationT he transfer of assets upon death by residents of Puerto Rico ( PR ) may be subject to estate taxes imposed by the United
US and PR Estate Tax considerations for Puerto Rico Residents Born in PR or Who Acquired US Citizenship Solely by Residency in PR (PR Persons) By: Ricardo Muñiz, Esq. T he transfer of assets upon death
More informationBARBER EMERSON, L.C. MEMORANDUM ESTATE FREEZING THROUGH THE USE OF INTENTIONALLY DEFECTIVE GRANTOR TRUSTS
BARBER EMERSON, L.C. MEMORANDUM ESTATE FREEZING THROUGH THE USE OF INTENTIONALLY DEFECTIVE GRANTOR TRUSTS I. INTRODUCTION AND CIRCULAR 230 NOTICE A. Introduction. This Memorandum discusses how an estate
More information20. Income Tax Consequences at Death
20. Income Tax Consequences at Death When you die, your income tax situation changes: your estate becomes a separate taxpayer and your tax situation is more complicated. However, the situation also presents
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 informationI CAN T GET NO CLATISFACTION. By Dan Rice INDEX. 1. Presentation Synopsis...Pages 2 5
I CAN T GET NO CLATISFACTION By Dan Rice INDEX 1. Presentation Synopsis......Pages 2 5 2. Charitable Lead Annuity Trusts Planning Strategies Part 1... Pages 6 9 3. Charitable Lead Annuity Trust Planning
More information36 TH ANNUAL PHILLIP E. HECKERLING INSTITUTE ON ESTATE PLANNING
36 TH ANNUAL PHILLIP E. HECKERLING INSTITUTE ON ESTATE PLANNING CHAPTER 10 Coordinating Income Tax Planning with Estate Planning: Uses of Installment Sales, Private Annuities and Self-Canceling Installment
More informationPresentations also allow you to add an introductory note specifically for the client receiving the presentation.
Firm Name Team Name (if one) CPA Planner Name, Credentials Title Street Address City, NY 13160 Phone number xext # Alternate phone # address@email.com website URL Estate Tax Presentations also allow you
More informationIRAs as Shareholders in Subchapter S Corporations Who Is An Individual?
IRAs as Shareholders in Subchapter S Corporations Who Is An Individual? 2321 N. Loop Drive, Ste 200 Ames, Iowa 50010 www.calt.iastate.edu October 1, 2009 by Roger A. McEowen* Updated on March 26, 2012
More informationCross Species Conversions and Mergers
Cross Species Conversions and Mergers 591 Cross Species Conversions and Mergers JOHN B. TRUSKOWSKI * The adoption by many states of both conversion statutes 1 statutes allowing one form of business organization,
More informationTAX-QUALIFIED LONG TERM CARE INSURANCE
TAX-QUALIFIED LONG TERM CARE INSURANCE If you have questions, call the Genworth Advanced Marketing team at 800 532.9116 or e-mail us at advanced.marketing@genworth.com 2008 TAX INFORMATION Underwritten
More informationAdvanced Markets Combining Estate Planning Techniques A Powerful Strategy
Life insurance can help meet many wealth transfer goals. The death benefit could cover estate taxes, for instance, avoiding liquidation of much of the estate to meet the estate tax bill. Even though a
More informationBusiness Succession Planning. 2011 Morgan Stanley Smith Barney LLC. Member SIPC
2011 Morgan Stanley Smith Barney LLC. Member SIPC 2011-PS-541 Expires: February 2012 Date of First Use: February 2011 Updated/Reviewed: February 2011 Overview Why Succession Planning is Important Common
More informationAccounting Periods and Methods
Department of the Treasury Internal Revenue Service Publication 538 (Rev. December 2012) Cat. No. 15068G Accounting Periods and Methods Contents Introduction... 1 Reminders... 2 Accounting Periods... 2
More informationdeduction, as well as any additional relief provided for in any applicable tax treaty between Canada and the other country.
TAX NEWSLETTER Special Release: August 2008 REAL OPPORTUNITY: CANADIANS & U.S. REAL ESTATE The weak U.S. economy, the recent subprime mortgage crisis and the strength of the Canadian dollar relative to
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 informationExecutive Summary of the Defined Benefit Plan Engineering Financial and Economic Security for Multiple Generations
Executive Summary of the Defined Benefit Plan Engineering Financial and Economic Security for Multiple Generations Benefit Focused vs. Lump Sum Focused Overview: What distinguishes a retirement plan which
More informationTAXATION OF REGULATED INVESTMENT COMPANIES
TAXATION OF REGULATED INVESTMENT COMPANIES January 2012 J. Walker Johnson and Alexis MacIvor I. In General A. Economic functions 1. Pooling of investments 2. Investment diversity 3. Investment advice and
More informationState Estate Taxes BECAUSE YOU ASKED ADVANCED MARKETS
ADVANCED MARKETS State Estate Taxes In 2001, President George W. Bush signed the Economic Growth and Tax Reconciliation Act (EGTRRA) into law. This legislation began a phaseout of the federal estate tax,
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 informationDivorce and Life Insurance. in brief
Divorce and Life Insurance in brief Divorce and Life Insurance Introduction In a divorce, property is divided between the spouses. In addition, a divorce decree may require that one spouse pay alimony
More informationEstate & Gift Tax Treatment for Non-Citizens
ADVANCED MARKETS Estate & Gift Tax Treatment for Non-Citizens It goes without saying that the laws governing the U.S. estate and gift tax system are complex. When you then consider the additional complexities
More informationUNITED STATES HOLOCAUST MEMORIAL MUSEUM
Honor the last generation. Enlighten the next. Leave a legacy bequest to the Museum. Retirement Plan Assets: A Smart Way to Secure Your Legacy UNITED STATES HOLOCAUST MEMORIAL MUSEUM 100 Raoul Wallenberg
More informationHandling the Complexities of Planning With Annuities
Handling the Complexities of Planning With Annuities Although commercial annuities are popular investments for seniors, these assets can be complex and are often misunderstood. This article explores planning
More informationPrivate Annuities a Simple Strategy for Estate Planning, Business Succession Planning, and Asset Protection
Chapter 41 Private Annuities a Simple Strategy for Estate Planning, Business Succession Planning, and Asset Protection Ryland F. Mahathey (Boca Raton, Florida) A sale for a private annuity describes a
More informationInvestment Objectives and Management
DISCLOSURE STATEMENT DESERET POOLED INCOME FUND The Corporation of the President of the Church of Jesus Christ of Latter-day Saints (the "Church") has created the Deseret Pooled Income Fund, (the "Fund")
More informationDistributions and Rollovers from
Page 1 of 6 Frequently Asked Questions about Distributions and Rollovers from Retirement Accounts Choosing what to do with your retirement savings is an important decision. Tax implications are just one
More informationInstructions for Completing Indiana Inheritance Tax Return
Instructions for Completing Indiana Return This form does not need to be completed for those individuals dying after Dec. 31, 2012. For those individuals dying before Jan. 1, 2013, this form may need to
More informationA Practical Guide to the Final Regs. Governing Split- Dollar Life Insurance
PERSONAL A Practical Guide to the Final Regs. Governing Split- Dollar Life Insurance Author: By Gary Lee and Deborah Walker GARY LEE is National Director of Insurance Consulting Services for Deloitte &
More informationIncome Tax Exit Strategies for the Closely-Held Business Upon the Retirement of a Principal Owner
Income Tax Exit Strategies for the Closely-Held Business Upon the Retirement of a Principal Owner by Jerome M. Hesch Of Counsel Berger Singerman, P.A. Miami, Florida Director Notre Dame Tax and Estate
More informationCasualty Loss Deductions for Tax Purposes
Casualty Loss Deductions for Tax Purposes Taxloss.cas The tremendous property damage caused by hurricane Floyd, and earlier Dennis, to homeowners and businesses has spawned numerous tax-related questions.
More informationBy Edward L. Perkins, JD, LLM. CPE CREDIT - 1.0 Hour of Interactive Self-Study
Estate Planning After the Tax Relief Act of 2010 What to Do? By Edward L. Perkins, JD, LLM CPE CREDIT - 1.0 Hour of Interactive Self-Study FIELD OF STUDY - Taxation PROGRAM LEVEL - Intermediate PREREQUISITE
More informationWhat s News in Tax Analysis That Matters from Washington National Tax
What s News in Tax Analysis That Matters from Washington National Tax Stock Option Compensation Warnings for the Unwary Stock options are a popular form of compensation provided to employees of corporations.
More informationcommittee report Life Insurance In Qualified Plans insurance
committee report insurance Life Insurance In Qualified Plans For business owners, it s sometimes a good idea but sometimes not. Know the trade-offs By Carolyn Lloyd- Cohen, principal, Carolyn Lloyd-Cohen
More informationIrrevocable Life Insurance Trust (ILIT)
THE WEALTH COUNSELOR LLC Irrevocable Life Insurance Trust (ILIT) What Is the Irrevocable Life Insurance Trust? An irrevocable trust is one in which the grantor completely gives up all rights in the property
More informationBalancing Bet-to Strategies
Balancing Bet-to to-live and Bet-to to-die Strategies Presented By: Robert S. Keebler, CPA, MST, AEP Stephen J. Bigge, CPA CSEP Phone: (920) 593-1701 E-mail: robert.keebler@keeblerandassociates.com Circular
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 informationAdvanced Designs. Pocket Guide. Private Split-Dollar Life Insurance Designs AD-OC-724B
Advanced Designs Pocket Guide Private Split-Dollar Life Insurance Designs AD-OC-724B This material is not intended to be used, nor can it be used by any taxpayer, for the purpose of avoiding U.S. federal,
More informationFEDERAL INCOME TAXES FOR TIMBER GROWERS
NC STATE UNIVERSITY COLLEGE OF AGRICULTURE & LIFE SCIENCES FEDERAL INCOME TAXES FOR TIMBER GROWERS Contents 2 Introduction Definition of timber Gain or loss from sale of timber Gross sales receipts Minus:
More informationTake That, Private Annuities IRS Issues Proposed Regulations Podcast of October 21, 2006
Take That, Private Annuities IRS Issues Proposed Regulations Podcast of October 21, 2006 Feed address for Podcast subscription: http://feeds.feedburner.com/edzollarstaxupdate Home page for Podcast: http://ezollars.libsyn.com
More information