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 March 14, 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
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
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
Grantor-retained annuity trusts — commonly referred to as “GRATs” — have been in the cross-hairs of the Internal Revenue Service (IRS), Congress and the Obama Administration for some time. This is because of the increased use of short-term GRATs with zero-remainder interests, resulting in no gift tax upon the creation
Published on January 28, 2011
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 April 16, 2014
IRS Issues Partnership Anti-Abuse Rule Regs.
The IRS and Treasury issued final regulations on June 8 to provide that the Sec. 704(c) anti-abuse rule takes into account the tax liabilities of both partners and certain owners of partners (T.D. 9485). The regulations also provide that partnerships cannot use an allocation method to achieve tax results that
Published on August 01, 2010
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
Like-Kind Exchanges Deferral Is Not Always the Best Option
Sec. 1031 gives taxpayers the opportunity to defer taxation on the gains they may have on their transactions. Anytime there is an opportunity to defer tax costs, tax practitioners and their clients automatically tend to assume that they should take advantage of the opportunity. However, in the case of like-kind
Published on January 28, 2011