Due to historically low rates combined with potentially depressed asset values due to the recent market decline, now may present an unparalleled opportunity to take advantage of wealth transfer techniques to shift significant wealth downstream with little to no use of gift tax exemption. As I write the article, the United States and the rest of…
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In a recent Tax Court Memorandum opinion, the Court was not too pleased with the operations and the administrative proceedings of the IRS involving Notices of Deficiency issued to a taxpayer. The taxpayer represented himself and was subjected to a confusing series of communications with the IRS causing the Court to sympathize with the taxpayer in…
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I was fortunate enough to attend the 54th annual Heckerling Institute on Estate Planning in Orlando. Heckerling is known worldwide for being one of the most innovative and informative estate planning conferences put on. The topics are always relevant and timely, and there are always some new and innovative planning techniques and ideas presented. Additionally,…
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On December 20, 2019, President Donald Trump signed the Setting Every Community Up for Retirement (Secure) Act into law as part of the year-end spending bill. The Secure Act (the “Act”) goes into effect on January 1, 2020 and makes a host of changes to retirement plan laws. Among these changes are significant changes to…
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As the race for the Democratic nomination for President heats up and the first primary election taking place in just 3 months, candidates have begun to release more details about their proposed tax plans. While these proposed plans will undoubtedly evolve and change over time and are of course subject to being passed by Congress,…
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The Tax Cut and Jobs Act (“TCJA”) enacted some sweeping changes to our nation’s tax laws. One major change was the modification of Section 2010 to increase in the individual estate tax exemption from $5M, indexed for inflation ($5.49M in 2017), to $10M, indexed for inflation ($11.2M in 2018, 11.4M in 2019). Thus couples went…
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One of the more common engagements for our firm is to assist with business sales and acquisitions. This article is the fifth in a series of articles which will walk through and generally discuss the steps typically associated with the sale of a business. In Part 1, we discussed the breakdown of the business, the…
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A common form of compensation for management and executive level employees is a grant of equity in the employer company, or the option to purchase such equity at a reduced price. Compensation in the form of equity can be a big incentive for employees to join a new company, particularly a startup, or stay at…
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In a recent opinion handed down by the United States District Court for the District of New Jersey, the Court dismissed the taxpayer’s suit for a refund on the basis of lack of jurisdiction. The Court found the taxpayer failed to file the suit for a refund within the two year deadline set forth by…
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In a recent Memorandum opinion issued by the Tax Court, the Court held that the 60-day time limit for individual retirement account (“IRA”) rollovers was met for a distribution and subsequent recontribution of IRA funds despite the funds not being credited back to the IRA upon recontribution until 62 days after the initial distribution. The IRS…
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