Payments for Future Remediation Expenses Are Not Insurance Premiums
...Rul. 2007-47 that payments to an insurance company to cover future capped costs were not insurance payments for tax purposes. The "premium" was an amount equal to the present value of estimated f
Published on April 19, 2010
Computing the Charitable Tax Deduction for a Charitable Remainder Trust
The methods for calculating a charitable remainder annnuity trust and a charitable remainder unitrust are different because the CRUT income stream fluctuates with changes in the value of the trust property. The technicalities involved in determining the value of the income stream or the remainder interest are much more complex
Published on February 28, 2014
Golden Parachute Calculations 10 Misunderstood Aspects of Secs. 280G and 4999
When a company experiences a change in control, the golden parachute rules are intended to discourage excessive compensation for “disqualified individuals” by imposing adverse tax consequences on both the company and the disqualified individuals.
Published on July 23, 2013
Partnership Capital Account Revaluations An In-Depth Look at Sec. 704(c) Allocations
Sec. 704(c) aims to prevent the shifting of gain, loss, or other tax attributes among partners by mandating certain adjustments to partners' capital accounts.
Published on February 04, 2014
Computing the Includible Portion for Graduated GRATs
Recent regulations provide practitioners a reminder that planning discussions with clients considering graduated GRATs should include a review of the potential consequences presented if the grantor dies prematurely
Published on July 25, 2013
IRS Issues New Rules on Allocation of Partnership Items
Proposed regulations under Sec. 704(c) provide that the Sec. 704(c) anti-abuse rule takes into account the tax liabilities of both the partners in a partnership and certain direct and indirect owners of such partners.
Published on May 02, 2010
Now Is the Time Converting a C Corporation to an S Corporation or LLC
The current uncertain economic environment may present an opportunity to exit C status and its attendant double taxation at an acceptable current tax cost
Published on July 30, 2013
Substantial Compliance Insufficient to Allow Charitable Deduction
The Seventh Circuit has held that the doctrine of substantial compliance would not allow a trust to take a charitable deduction where the trustee had intended, but failed, to reform the trust as a charitable remainder unitrust.
Published on May 10, 2010
The Codified Economic-Substance Doctrine and Captive Insurance Companies
In light of the lack of guidance on whether the new codified economic-substance rules apply to captive insurance companies, it is prudent to assume that the law does apply.
Published on August 31, 2012
Determining the Correct FMV of Private Company Stock When Stock Options Are Granted
...stock option is granted to an employee, great care must be taken to ensure that the exercise price is equal to or greater than the stock's fair market value (FMV) on the option's grant date. If the exercise price is lower than the FMV, resulting in a "discounted
Published on January 28, 2011