The Internal Revenue Service recently issued some private letter rulings (PLRs) that shed light on its thinking on the trust payment of estate expenses, non-taxable trustee-to-trustee transfers, lump sum distributions and waivers of the 60-day...
The American Jobs Creation Act also tightened rules for charitable contributions of vehicles and patents. As David T. Leibell and Daniel L. Daniels of Cummings & Lockwood LLC in Stamford, Conn., report: Buried in the 600 pages of the act are two...
Since 1986, 23 jurisdictions in the United States have abrogated or modified the rule against perpetuities, the injunction that prevents trusts from continuing without end. More states are considering doing so. What's driving this fundamental...
The American Jobs Creation Act of 2004, signed into law Oct. 22, made some key changes to the S Corporation rules. As David A. Handler, in the Chicago office of Kirkland & Ellis LLP, reports: Internal Revenue Code Section 1361(b)(1)(A) provides...
The American Jobs Creation Act of 2004 signed by President Bush on Oct. 22 expands the number of people subject to the 10-year expatriation tax after they renounce their U.S. citizenship or end their long-term residency. It also expands the amount...
Most compliance issues arise in private foundations because the family members and directors don't know much about the governing provisions set forth in the Internal Revenue Code and Treasury Regulations. This is hardly surprising, given that most...
Advisors to U.S. clients increasingly are faced with questions regarding the U.S. gift, estate, generation skipping transfer (GST) and income tax consequences of transfers from non-resident aliens to, or for, the benefit of their U.S. clients...
Under Internal Revenue Code Section 2642(f)(1), the grantor of a trust cannot effectively allocate generation-skipping transfer (GST) tax exemption to property transferred until the close of the estate tax inclusion period (ETIP). The ETIP is the...
Anyone who has ever let household chores get the better of him is well-acquainted with the most significant obstacle facing wannabe high-net-worth advisors: inertia. You can look at those cracks in the bedroom ceiling every day when you lie down...
The image of the strong, silent loner is a powerful one in this country, but it loses some of its potency when applied to the modern brokerage industry as Ray Ferrara can attest. Ferrara started out his career as a solo practitioner in Clearwater...
