The proposed regulations from the Treasury Department would greatly restrict the availability of valuation discounts for family-controlled entities. This could significantly increase some families' federal estate tax exposure by limiting discounts that allow more wealth to pass to heirs outside of estate taxes. The proposed regulations would disregard many restrictions that currently result in valuation discounts and contain broad family attribution rules. Key considerations for families include whether federal estate taxes are a current risk and whether planning strategies should be implemented in light of the potential changes to current estate planning laws if the regulations are finalized.
The IRS is pursing all manner of estate planning transactions involving family-controlled entities ("FCEs") and now has gone straight to the heart of the matter - valuation.
This document discusses strategies for tax-smart investing to help investors keep more of their investment gains. It notes that taxes can significantly erode investment returns over time if not properly managed. The tax code is also evolving, with rates expected to increase in the future. The document recommends adopting a consistent, year-round approach to tax management using available tools from investment managers, such as tax-lot accounting and tax-managed funds, to help offset the effects of taxes and ease uncertainty.
The document summarizes key tax changes resulting from the American Taxpayer Relief Act of 2012, which addressed the fiscal cliff. Two new taxes take effect in 2013 - a 3.8% Net Investment Income Tax on investment income above thresholds and a 0.9% additional Medicare tax on wages above thresholds. The top capital gains and dividend tax rate increases to 20% for income above $400,000/$450,000. Estate and gift tax exemptions remain at $5.25 million and the top rate is 40%. Itemized deductions are reduced for incomes above $250,000/$300,000.
New Legislation Enhances the Benefits of a Section 1042 Tax-Deferred SaleChristopher T. Horner II
Recent tax legislation increased income tax rates, making tax-deferred sales to ESOPs more advantageous for business owners seeking to diversify or exit their businesses. A Section 1042 tax-deferred sale allows shareholders to defer or eliminate capital gains tax by selling stock to an ESOP and reinvesting the proceeds in qualified replacement property. The key benefits are deferring tax liability until the replacement property is sold and obtaining a stepped-up tax basis in the replacement property if held until death. However, not all business owners qualify for Section 1042 treatment, and deferred gains must eventually be recognized if replacement property is sold or otherwise disposed of.
Retaining Wealth in a Rising Tax Environmentbruce_gillen
Tax rates are expected to rise in 2011 as Bush-era tax cuts expire. This will negatively impact high-income taxpayers through higher income, capital gains, and dividend tax rates. The document discusses three strategies for improving tax efficiency despite rising rates: 1) minimizing short-term capital gains distributions through manager incentives and technology; 2) investing in dividend-paying stocks for qualified dividends taxed at a lower rate; and 3) municipal bonds which provide tax-exempt income but require credit research expertise. It emphasizes the benefits of tax-efficient strategies, especially for accumulation and distribution phases of investing.
The Fiscal Cliff and 10 Moves Every Investor Should Consider Making Now (...B...D.B. Geehan
Originally published Oct 2012 -- White Paper regarding moves every investor should consider making in the run-up to December 31, 2012 and the Fical Cliff.
This document provides an overview of various year-end planning strategies for 2010 related to taxes, investments, estate planning, and charitable giving. It notes the uncertainty around future federal tax rates and recommends considering strategies like harvesting tax losses, accelerating or deferring income and deductions, and making gifts before the end of the year. Specific strategies mentioned include Roth IRA conversions, exercising stock options, timing of charitable donations, and using trusts. The document emphasizes planning soon given the short timeline before year's end.
The IRS is pursing all manner of estate planning transactions involving family-controlled entities ("FCEs") and now has gone straight to the heart of the matter - valuation.
This document discusses strategies for tax-smart investing to help investors keep more of their investment gains. It notes that taxes can significantly erode investment returns over time if not properly managed. The tax code is also evolving, with rates expected to increase in the future. The document recommends adopting a consistent, year-round approach to tax management using available tools from investment managers, such as tax-lot accounting and tax-managed funds, to help offset the effects of taxes and ease uncertainty.
The document summarizes key tax changes resulting from the American Taxpayer Relief Act of 2012, which addressed the fiscal cliff. Two new taxes take effect in 2013 - a 3.8% Net Investment Income Tax on investment income above thresholds and a 0.9% additional Medicare tax on wages above thresholds. The top capital gains and dividend tax rate increases to 20% for income above $400,000/$450,000. Estate and gift tax exemptions remain at $5.25 million and the top rate is 40%. Itemized deductions are reduced for incomes above $250,000/$300,000.
New Legislation Enhances the Benefits of a Section 1042 Tax-Deferred SaleChristopher T. Horner II
Recent tax legislation increased income tax rates, making tax-deferred sales to ESOPs more advantageous for business owners seeking to diversify or exit their businesses. A Section 1042 tax-deferred sale allows shareholders to defer or eliminate capital gains tax by selling stock to an ESOP and reinvesting the proceeds in qualified replacement property. The key benefits are deferring tax liability until the replacement property is sold and obtaining a stepped-up tax basis in the replacement property if held until death. However, not all business owners qualify for Section 1042 treatment, and deferred gains must eventually be recognized if replacement property is sold or otherwise disposed of.
Retaining Wealth in a Rising Tax Environmentbruce_gillen
Tax rates are expected to rise in 2011 as Bush-era tax cuts expire. This will negatively impact high-income taxpayers through higher income, capital gains, and dividend tax rates. The document discusses three strategies for improving tax efficiency despite rising rates: 1) minimizing short-term capital gains distributions through manager incentives and technology; 2) investing in dividend-paying stocks for qualified dividends taxed at a lower rate; and 3) municipal bonds which provide tax-exempt income but require credit research expertise. It emphasizes the benefits of tax-efficient strategies, especially for accumulation and distribution phases of investing.
The Fiscal Cliff and 10 Moves Every Investor Should Consider Making Now (...B...D.B. Geehan
Originally published Oct 2012 -- White Paper regarding moves every investor should consider making in the run-up to December 31, 2012 and the Fical Cliff.
This document provides an overview of various year-end planning strategies for 2010 related to taxes, investments, estate planning, and charitable giving. It notes the uncertainty around future federal tax rates and recommends considering strategies like harvesting tax losses, accelerating or deferring income and deductions, and making gifts before the end of the year. Specific strategies mentioned include Roth IRA conversions, exercising stock options, timing of charitable donations, and using trusts. The document emphasizes planning soon given the short timeline before year's end.
This document presents the 2-3-4 Financial Concept which provides a simplified approach to financial planning. It outlines two pyramids to establish goals, three buckets to categorize goals by time horizon, and four boxes to understand tax implications. The concepts can help with needs analysis, portfolio allocation, and choosing suitable products. Hypothetical examples illustrate how taxes impact returns in different investment vehicles during accumulation and distribution phases. The document notes it does not provide legal or tax advice.
The right tax strategy stays current with your environment.
The political landscape isn’t the only thing changing in
2016. Estate planning opportunities are also shifting. This
supplement incorporates estate planning updates and other
considerations into tips designed to decrease your 2016 tax
bill. Charts throughout the supplement, including tax rates,
qualified retirement plan limitations and FICA/Medicare
taxes further help with your tax planning.
This document discusses retirement plan distribution options and how to invest distributions. It provides three main distribution alternatives: lump-sum distributions, rolling over to an IRA, or leaving the money in the plan. It notes tax and penalty consequences of each option and emphasizes the benefits of rolling over funds to an IRA to avoid taxes and continue tax-deferred growth. It also provides tips on selecting investments and discusses risks and rewards associated with different asset classes.
The document summarizes key changes from the American Taxpayer Relief Act of 2012 and provides 13 financial planning strategies to consider in response. Some of the major tax changes include higher income tax rates for top earners, increased capital gains and dividend taxes, and new Medicare taxes. The strategies suggest reviewing one's portfolio to optimize its tax efficiency, taking advantage of tax-deferred growth options, and considering Roth conversions.
The document is a newsletter from a financial services company providing information and advice to clients. It discusses several tax tips that clients should consider before the end of the year, including accelerating deductions, bunching deductions, maximizing retirement contributions, checking exposure to the Alternative Minimum Tax, making charitable donations and family gifts, and assessing capital gains and losses. It also summarizes recent IRS guidance on taking distributions from retirement plans with both pre-tax and after-tax balances.
How to transform a family business: insights from the trenches Browne & Mohan
The document discusses insights into transforming a family business. It begins by providing background on the prevalence of family businesses globally and in India. It then outlines some of the common challenges family businesses face, such as unclear roles and decision-making bottlenecks. The document recommends conducting an assessment of the family business' "maturity" to identify gaps. It suggests transformations on both the family side, such as establishing governance structures and succession planning, and the business side, like evaluating operations and investing in capabilities. The goal is to professionalize processes while preserving family identity.
The document provides an overview of helpful tax tips and savings opportunities for the 2016 tax season, presented by Monica Silwanowicz. It discusses limitations on itemized deductions, personal exemptions, and the alternative minimum tax. It also covers opportunities like donating appreciated assets to charity, qualified charitable distributions from IRAs, and potential impacts of tax reform proposals on businesses, individuals, itemized deductions, and estate taxes. The document aims to help taxpayers maximize deductions and plan effectively for the upcoming tax year.
This document provides an overview and tips for 2017 individual tax planning. It summarizes key tax rates, deductions, credits, and strategies to consider for reducing tax liability for the year. Potential tax reform proposals could change rates and provisions for 2018, so the document recommends planning based on current tax law and taking advantage of opportunities before year-end 2017 to be effective in mitigating taxes. It includes charts outlining various tax rates, limits, phaseouts and considerations for married and unmarried filers.
Increasing capital gains taxes would discourage investment when it is most needed to spur economic growth and job creation. [1] Studies have found that lower capital gains tax rates enhance economic growth and encourage entrepreneurship, benefiting all taxpayers with investments. [2] Higher capital gains tax rates cause lower levels of new venture funding and impact entrepreneurship decisions, which can impede job creation. [3] In short, increasing investment taxes is counterproductive for business and the economy.
Estate Planning for Owners of Closely-Held BusinessesMoskowitz LLP
Estate planning for owners of closely-held businesses is designed to avoid unintended consequences. The death of an owner can have significant estate and gift tax consequences that can be mitigated with lifetime and postmortem estate planning techniques.
This presentation and these materials are designed to provide information in regard to the subject matter
covered. This presentation and these materials are provided solely as a teaching tool, with the
understanding that Stephen Moskowitz, Moskowitz LLP, and the instructor are not engaged in rendering
legal, accounting, or other professional service and that they are not offering such advice in this
presentation and these accompanying materials.
The document summarizes key elements of the new tax law that impact partnerships, S corporations, and pass-through income. It discusses:
1) A new 20% deduction for qualified business income from pass-through entities, subject to limitations for higher-income taxpayers and service businesses.
2) Rules allowing S corporations converting to C corporations to take accumulated adjustments into account over 6 years.
3) Repeal of the technical termination rule for partnerships that experienced 50% changes in capital/profits interests.
4) Changes to partnership loss limitation rules regarding charitable contributions and foreign taxes.
5) A look-through rule treating gains/losses on partnership interest sales as effectively connected to a U.
Here's a look at some of the more important elements of the new tax law that have an impact on partnerships, S corporations, and pass-through income. In general, they are effective starting in 2018.
This document provides information about stretch IRAs, including:
- A stretch IRA is a strategy to extend the tax-deferred growth of IRA assets by distributing them over a beneficiary's lifetime based on their life expectancy tables.
- Required minimum distributions must be taken from traditional IRAs starting at age 70 1/2, but these distributions can be spread out over many years, allowing the IRA to continue growing.
- The main options for beneficiaries of a traditional IRA are lump sums, 5-year distributions, or life expectancy distributions stretched over the beneficiary's lifetime.
- Proper beneficiary designations are important for achieving stretch IRA goals and ensuring tax-efficient distributions over generations.
InfraREIT reported solid first quarter 2018 results with increased lease revenue and net income. Management is evaluating terminating the company's REIT status and pursuing an alternative corporate structure. The board has directed pursuing a C-corp structure but has not set a timeline. InfraREIT reaffirmed 2018 guidance and expects $70-180 million in footprint capital expenditures from 2018-2020.
This document provides information on 2021 tax planning strategies for individuals and businesses. It discusses the difference between reactive tax preparation and proactive tax planning. The stages of effective tax planning include planning, implementation, quarterly maintenance, and tax return preparation. Various tax planning strategies are outlined for deferring or accelerating income, bunching deductions, maximizing retirement contributions, checking IRA distribution requirements, converting traditional IRAs to Roth IRAs, and reducing Roth conversion taxes. Year-end tax planning considerations for businesses include employee retention credits, net operating loss carrybacks, and research and development cost deductions and amortization.
This Week's White Paper Wednesday Project is from Michael Weiner, CFA, Chief Investment Officer @ Unified Trust Company.
According to multiple surveys, somehow accumulating
enough assets to retire comfortably, given all other
demands on our savings, remains a top five concern of
Americans. This is a major reason why Cash Balance
plans are on the rise throughout the U.S. and why it
may be something to consider for your business both
from a tax efficiency (Buffet style) and a retirement
savings perspective.
1. The document discusses a Deferred Sales Trust (DST) as a way for property owners to defer capital gains taxes when selling highly appreciated assets like real estate.
2. A DST allows the seller to defer capital gains taxes over a period of time by selling the property to a trust, which then pays the seller in installments according to a contract.
3. Benefits of a DST include tax deferral, estate tax benefits, maintaining family wealth, estate liquidity, and retirement income. It also eliminates risks of ownership by converting an illiquid asset into monthly payments.
Increase Profit and Make Better Business Decisions through your Tax Services Moskowitz LLP
Year-round tax planning with Mosokowitz LLP; The road to tax savings begins with us!
This presentation and these materials are designed to provide information in regard to the subject matter
covered. This presentation and these materials are provided solely as a teaching tool, with the
understanding that Stephen Moskowitz, Moskowitz LLP, and the instructor are not engaged in rendering
legal, accounting, or other professional service and that they are not offering such advice in this
presentation and these accompanying materials.
Strategies to Maximize Employee Retention Credit and Paycheck Protection Program (PPP) Forgiveness.
This presentation and these materials are designed to provide information in regard to the subject matter
covered. This presentation and these materials are provided solely as a teaching tool, with the
understanding that Stephen Moskowitz, Moskowitz LLP, and the instructor are not engaged in rendering
legal, accounting, or other professional service and that they are not offering such advice in this
presentation and these accompanying materials.
O documento discute os modelos atômicos de Dalton, Thomson e Rutherford, além de propriedades dos átomos e elementos. As principais ideias apresentadas são: 1) O experimento de Rutherford mostrou que os átomos possuem um núcleo denso de carga positiva; 2) O modelo de Dalton não explicava os desvios das partículas alfa no experimento de Rutherford; 3) Observações experimentais como a conservação da massa apoiaram a adoção de modelos atômicos.
Este documento resume los conceptos clave de ética civil, responsabilidad civil, derechos humanos y mecanismos de defensa de los derechos humanos según la constitución y legislación colombianas. También analiza brevemente la relación entre la ética civil y la película "Rojo como el cielo" con respecto a la violación de los derechos de un niño ciego y el deber de una madre de trabajar para sustentar a su familia.
This document presents the 2-3-4 Financial Concept which provides a simplified approach to financial planning. It outlines two pyramids to establish goals, three buckets to categorize goals by time horizon, and four boxes to understand tax implications. The concepts can help with needs analysis, portfolio allocation, and choosing suitable products. Hypothetical examples illustrate how taxes impact returns in different investment vehicles during accumulation and distribution phases. The document notes it does not provide legal or tax advice.
The right tax strategy stays current with your environment.
The political landscape isn’t the only thing changing in
2016. Estate planning opportunities are also shifting. This
supplement incorporates estate planning updates and other
considerations into tips designed to decrease your 2016 tax
bill. Charts throughout the supplement, including tax rates,
qualified retirement plan limitations and FICA/Medicare
taxes further help with your tax planning.
This document discusses retirement plan distribution options and how to invest distributions. It provides three main distribution alternatives: lump-sum distributions, rolling over to an IRA, or leaving the money in the plan. It notes tax and penalty consequences of each option and emphasizes the benefits of rolling over funds to an IRA to avoid taxes and continue tax-deferred growth. It also provides tips on selecting investments and discusses risks and rewards associated with different asset classes.
The document summarizes key changes from the American Taxpayer Relief Act of 2012 and provides 13 financial planning strategies to consider in response. Some of the major tax changes include higher income tax rates for top earners, increased capital gains and dividend taxes, and new Medicare taxes. The strategies suggest reviewing one's portfolio to optimize its tax efficiency, taking advantage of tax-deferred growth options, and considering Roth conversions.
The document is a newsletter from a financial services company providing information and advice to clients. It discusses several tax tips that clients should consider before the end of the year, including accelerating deductions, bunching deductions, maximizing retirement contributions, checking exposure to the Alternative Minimum Tax, making charitable donations and family gifts, and assessing capital gains and losses. It also summarizes recent IRS guidance on taking distributions from retirement plans with both pre-tax and after-tax balances.
How to transform a family business: insights from the trenches Browne & Mohan
The document discusses insights into transforming a family business. It begins by providing background on the prevalence of family businesses globally and in India. It then outlines some of the common challenges family businesses face, such as unclear roles and decision-making bottlenecks. The document recommends conducting an assessment of the family business' "maturity" to identify gaps. It suggests transformations on both the family side, such as establishing governance structures and succession planning, and the business side, like evaluating operations and investing in capabilities. The goal is to professionalize processes while preserving family identity.
The document provides an overview of helpful tax tips and savings opportunities for the 2016 tax season, presented by Monica Silwanowicz. It discusses limitations on itemized deductions, personal exemptions, and the alternative minimum tax. It also covers opportunities like donating appreciated assets to charity, qualified charitable distributions from IRAs, and potential impacts of tax reform proposals on businesses, individuals, itemized deductions, and estate taxes. The document aims to help taxpayers maximize deductions and plan effectively for the upcoming tax year.
This document provides an overview and tips for 2017 individual tax planning. It summarizes key tax rates, deductions, credits, and strategies to consider for reducing tax liability for the year. Potential tax reform proposals could change rates and provisions for 2018, so the document recommends planning based on current tax law and taking advantage of opportunities before year-end 2017 to be effective in mitigating taxes. It includes charts outlining various tax rates, limits, phaseouts and considerations for married and unmarried filers.
Increasing capital gains taxes would discourage investment when it is most needed to spur economic growth and job creation. [1] Studies have found that lower capital gains tax rates enhance economic growth and encourage entrepreneurship, benefiting all taxpayers with investments. [2] Higher capital gains tax rates cause lower levels of new venture funding and impact entrepreneurship decisions, which can impede job creation. [3] In short, increasing investment taxes is counterproductive for business and the economy.
Estate Planning for Owners of Closely-Held BusinessesMoskowitz LLP
Estate planning for owners of closely-held businesses is designed to avoid unintended consequences. The death of an owner can have significant estate and gift tax consequences that can be mitigated with lifetime and postmortem estate planning techniques.
This presentation and these materials are designed to provide information in regard to the subject matter
covered. This presentation and these materials are provided solely as a teaching tool, with the
understanding that Stephen Moskowitz, Moskowitz LLP, and the instructor are not engaged in rendering
legal, accounting, or other professional service and that they are not offering such advice in this
presentation and these accompanying materials.
The document summarizes key elements of the new tax law that impact partnerships, S corporations, and pass-through income. It discusses:
1) A new 20% deduction for qualified business income from pass-through entities, subject to limitations for higher-income taxpayers and service businesses.
2) Rules allowing S corporations converting to C corporations to take accumulated adjustments into account over 6 years.
3) Repeal of the technical termination rule for partnerships that experienced 50% changes in capital/profits interests.
4) Changes to partnership loss limitation rules regarding charitable contributions and foreign taxes.
5) A look-through rule treating gains/losses on partnership interest sales as effectively connected to a U.
Here's a look at some of the more important elements of the new tax law that have an impact on partnerships, S corporations, and pass-through income. In general, they are effective starting in 2018.
This document provides information about stretch IRAs, including:
- A stretch IRA is a strategy to extend the tax-deferred growth of IRA assets by distributing them over a beneficiary's lifetime based on their life expectancy tables.
- Required minimum distributions must be taken from traditional IRAs starting at age 70 1/2, but these distributions can be spread out over many years, allowing the IRA to continue growing.
- The main options for beneficiaries of a traditional IRA are lump sums, 5-year distributions, or life expectancy distributions stretched over the beneficiary's lifetime.
- Proper beneficiary designations are important for achieving stretch IRA goals and ensuring tax-efficient distributions over generations.
InfraREIT reported solid first quarter 2018 results with increased lease revenue and net income. Management is evaluating terminating the company's REIT status and pursuing an alternative corporate structure. The board has directed pursuing a C-corp structure but has not set a timeline. InfraREIT reaffirmed 2018 guidance and expects $70-180 million in footprint capital expenditures from 2018-2020.
This document provides information on 2021 tax planning strategies for individuals and businesses. It discusses the difference between reactive tax preparation and proactive tax planning. The stages of effective tax planning include planning, implementation, quarterly maintenance, and tax return preparation. Various tax planning strategies are outlined for deferring or accelerating income, bunching deductions, maximizing retirement contributions, checking IRA distribution requirements, converting traditional IRAs to Roth IRAs, and reducing Roth conversion taxes. Year-end tax planning considerations for businesses include employee retention credits, net operating loss carrybacks, and research and development cost deductions and amortization.
This Week's White Paper Wednesday Project is from Michael Weiner, CFA, Chief Investment Officer @ Unified Trust Company.
According to multiple surveys, somehow accumulating
enough assets to retire comfortably, given all other
demands on our savings, remains a top five concern of
Americans. This is a major reason why Cash Balance
plans are on the rise throughout the U.S. and why it
may be something to consider for your business both
from a tax efficiency (Buffet style) and a retirement
savings perspective.
1. The document discusses a Deferred Sales Trust (DST) as a way for property owners to defer capital gains taxes when selling highly appreciated assets like real estate.
2. A DST allows the seller to defer capital gains taxes over a period of time by selling the property to a trust, which then pays the seller in installments according to a contract.
3. Benefits of a DST include tax deferral, estate tax benefits, maintaining family wealth, estate liquidity, and retirement income. It also eliminates risks of ownership by converting an illiquid asset into monthly payments.
Increase Profit and Make Better Business Decisions through your Tax Services Moskowitz LLP
Year-round tax planning with Mosokowitz LLP; The road to tax savings begins with us!
This presentation and these materials are designed to provide information in regard to the subject matter
covered. This presentation and these materials are provided solely as a teaching tool, with the
understanding that Stephen Moskowitz, Moskowitz LLP, and the instructor are not engaged in rendering
legal, accounting, or other professional service and that they are not offering such advice in this
presentation and these accompanying materials.
Strategies to Maximize Employee Retention Credit and Paycheck Protection Program (PPP) Forgiveness.
This presentation and these materials are designed to provide information in regard to the subject matter
covered. This presentation and these materials are provided solely as a teaching tool, with the
understanding that Stephen Moskowitz, Moskowitz LLP, and the instructor are not engaged in rendering
legal, accounting, or other professional service and that they are not offering such advice in this
presentation and these accompanying materials.
O documento discute os modelos atômicos de Dalton, Thomson e Rutherford, além de propriedades dos átomos e elementos. As principais ideias apresentadas são: 1) O experimento de Rutherford mostrou que os átomos possuem um núcleo denso de carga positiva; 2) O modelo de Dalton não explicava os desvios das partículas alfa no experimento de Rutherford; 3) Observações experimentais como a conservação da massa apoiaram a adoção de modelos atômicos.
Este documento resume los conceptos clave de ética civil, responsabilidad civil, derechos humanos y mecanismos de defensa de los derechos humanos según la constitución y legislación colombianas. También analiza brevemente la relación entre la ética civil y la película "Rojo como el cielo" con respecto a la violación de los derechos de un niño ciego y el deber de una madre de trabajar para sustentar a su familia.
El documento describe el uso de foros como un recurso educativo para enseñar a estudiantes de quinto grado sobre nuevas tecnologías. Explica que los foros permiten la interacción y socialización entre estudiantes sobre estos temas de manera recreativa e innovadora. Luego, propone algunas estrategias como crear wikis, videos para YouTube y presentaciones en Prezi para involucrar a los estudiantes con programas en internet.
El documento describe diferentes tipos de resistencia a plagas en plantas, incluyendo resistencia horizontal, vertical, antibiosis, antixenosis y tolerancia. También describe métodos de transformación genética como electroporación, biobalística e infección con Agrobacterium. Luego discute el uso de genes Bt para resistencia a plagas y sus posibles efectos en depredadores y parasitoides no objetivos. Finalmente, presenta un estudio sobre los efectos del maíz Bt en la preferencia de presas y supervivencia de larvas del depredador Chrysoperla car
El documento describe las propuestas de reforma hacendaria del presidente EPN, incluyendo una posible generalización del IVA al 16% para financiar el sistema de seguridad social. Se presentan dos opciones para el IVA: 1) una tasa generalizada del 16% sin excepciones o 2) una tasa homologada pero con productos básicos exentos. También se discuten propuestas para eliminar el régimen de consolidación, aumentar el IVA y ISR, y mantener el IVA en 0% para alimentos básicos y medicinas.
El documento describe el sistema de numeración y las operaciones aritméticas básicas (suma, resta, multiplicación y división) utilizadas por los mayas. Los mayas utilizaban un sistema vigesimal posicional con tres símbolos básicos - punto (1), raya (5) y concha (0). La suma y resta se realizaban sumando y restando los valores de los símbolos. La multiplicación implicaba multiplicar cada componente del multiplicando por el multiplicador. La división se representaba colocando los números en forma horizontal, similar a la enseñada en las
Este documento proporciona instrucciones sobre cómo crear notas al pie en Microsoft Word. Explica que primero se debe seleccionar el texto que requiere aclaración, luego ir a Referencias y seleccionar la opción Nota al pie, y finalmente escribir el significado de esa palabra en la nota al pie.
Este documento discute los desafíos de la seguridad informática en las empresas, incluyendo amenazas como el hackeo de cuentas y la necesidad de proteger la información interna y externa. Describe estrategias comunes utilizadas por hackers como obtener información sobre la víctima, buscar puntos débiles y hacerse pasar por otras personas para ganar confianza. También cubre la importancia de analizar los riesgos, revisar la infraestructura actual y conocer las técnicas de ataque como recopilar información y planear con
O documento descreve a história da descoberta da radioatividade, as principais descobertas e cientistas envolvidos. Detalha os tipos de radiação alfa, beta e gama, suas propriedades e aplicações na medicina, datação e acidentes nucleares.
Este documento describe y compara varios medios de transmisión guiados y no guiados. Los medios guiados discutidos incluyen cable de par trenzado sin blindaje, cable de par trenzado con blindaje, cable coaxial y fibra óptica. Los medios no guiados incluyen ondas de radio, microondas, ondas infrarrojas, ondas de luz láser y satélites. Para cada medio, se describen sus características, ventajas y desventajas para la transmisión de datos.
El documento describe las funciones del juego en la infancia. Explica que el juego es una actividad inherente al ser humano que cumple funciones importantes en el desarrollo infantil como la exploración del mundo, la interacción social, el desarrollo motor y sensorial, y la estimulación de la creatividad y el pensamiento. También destaca que el juego es fundamental para el aprendizaje y que los adultos deben facilitarlo pero no dirigirlo.
Elementos de vinculación de las estrategias 2Wilmelia Bravo
El documento define las estrategias empresariales y de marketing, y explica que una estrategia es un conjunto de acciones planificadas para lograr un objetivo. Además, describe que los niveles estratégicos y la infraestructura operacional son elementos importantes para la ejecución estratégica de una organización.
O documento introduz conceitos fundamentais da economia, como escassez de recursos e necessidades humanas ilimitadas. Apresenta os problemas econômicos fundamentais de o que, quanto e como produzir e para quem, dada a escassez de recursos. Explica a diferença entre análise positiva e normativa na economia. Introduz os conceitos de microeconomia e como analisa a formação de preços nos mercados de bens e serviços e de fatores de produção.
Este documento resume la vida y carrera de la escritora española Carmen Laforet. Nació en 1921 en Barcelona y se mudó a Canarias a los 2 años antes de regresar a Barcelona en 1939. Publicó su novela más famosa, Nada, en 1944 a los 22 años, por la que ganó el Premio Nadal. Laforet escribió otras novelas como La isla y los demonios y La mujer nueva. A pesar de no terminar la carrera de Filosofía y Letras, Laforet tuvo una exitosa carrera como escritora.
O documento descreve a vida e obra de Leonardo da Vinci, um dos maiores gênios renascentistas. Ele nasceu na Itália em 1452 e trabalhou como pintor, anatomista, engenheiro e inventor. Suas obras mais famosas incluem a Mona Lisa e A Última Ceia. Da Vinci foi um homem de muitos talentos que contribuiu significativamente para o avanço das artes e ciências.
1. O documento apresenta números e termos técnicos referentes a um relatório financeiro.
2. Fornece detalhes sobre receitas, despesas e balanço patrimonial de uma empresa.
3. As informações são apresentadas de forma concisa em tabelas e gráficos.
O documento descreve uma nova linha de livros e kits de culinária da CookLovers, criada pelo Chef André Boccato, com o objetivo de facilitar e inspirar a culinária de forma prática, divertida e para toda a família. São apresentados diversos kits temáticos com livros de receitas e utensílios de cozinha a preços que variam entre R$49,90 e R$99,90.
O documento descreve o ciclo de transmissão de doenças através da água contaminada e da falta de saneamento adequado. As fezes humanas contaminam a água e o solo, permitindo que vermes e bactérias se espalhem e infectem outras pessoas que consomem a água ou entram em contato com o solo. Isso inicia um ciclo contínuo de disseminação de doenças como amebíase, giardíase e hepatite até que sejam tomadas medidas de saneamento e tratamento de água.
O documento lista vários projetos realizados em diferentes contextos como coquetéis, jantares, confraternizações, seminários, feiras, decoração, buffet, atrações, identidade visual, sinalização, design gráfico, brindes e uniformes.
The new U.S. tax law presents challenges for Canadian companies with operations in or exporting to the U.S. due to uncertain economic effects. While the corporate tax rate cut may initially raise valuations for domestic U.S. companies, different sectors will be impacted differently. Analyzing the full effects requires examining direct impacts of new rules as well as strategic corporate responses and potential retaliation from trading partners.
The document discusses the debate around taxing carried interest at ordinary income tax rates versus capital gains tax rates. Currently, carried interest is taxed as capital gains. Proponents of change argue this is unfair, as fund managers provide services, and their income should be taxed like other service providers at higher ordinary rates. However, opponents note that fund managers also take on investment risk like other investors. The document outlines the various perspectives in the debate and considers alternative proposals but does not take a definitive position.
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The document discusses how a Deferred Sales Trust (DST) can help clients defer capital gains taxes and reduce their overall tax burden when selling highly appreciated assets like homes, businesses, or real estate. A DST allows the seller to defer capital gains taxes until they receive payments from the trust over a chosen period of time. It converts the illiquid asset into a stream of monthly payments that can provide retirement income or be passed down to heirs. Key benefits include tax deferral, estate tax benefits, maintaining family wealth, estate liquidity, and probate avoidance. The DST purchases the asset from the seller via an installment sales agreement, then sells the asset and invests the proceeds to generate the cash flow needed to make payments to
AALU Washington Report: The Big Six’s “Unified” Tax Framework: Potential Impa...Fulcrum Partners LLC
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Mercer Capital's Value Matters™ | Issue No. 3, 2022|Mercer Capital
Mercer Capital's Value Matters™, published 6 times per year, addresses gift & estate tax, ESOP, buy-sell agreement, and transaction advisory topics of interest to estate planners and other professional advisors to business.
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The document discusses several ways that businesses can benefit from the new tangible property regulations in terms of tax savings. It explains that the regulations allow more expenses to be classified as deductible repairs rather than capitalized improvements. It also outlines various safe harbor elections that allow taxpayers to deduct costs that would otherwise be capitalized, such as improvement and materials expenses. In addition, it discusses opportunities to expense undepreciated costs of disposed assets using the partial disposition rule. Overall, the regulations can provide significant tax benefits if taxpayers properly analyze their expenditures under the new guidance.
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The document discusses uncertainty around potential federal estate tax repeal and provides recommendations for life insurance planning. It notes that while repeal seems imminent under the current administration, the estate tax has been repealed and reinstated before so future reinstatement is possible. It recommends that individuals incorporate flexibility into their life insurance plans through means like flexible irrevocable life insurance trusts in case the tax code changes. Permanent repeal may not occur and life insurance may still be needed to meet other wealth transfer goals even without the estate tax.
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The document discusses the Deferred Sales Trust (DST) as a strategy to defer capital gains taxes when selling appreciated assets like real estate. It explains that the DST allows the seller to transfer ownership of the property to a trust in exchange for a promissory note, deferred the capital gains tax until payments on the note are received. The trust then sells the property and uses the proceeds to invest and make scheduled payments to the seller over time according to the negotiated promissory note. This allows the seller to defer capital gains taxes for years while receiving a stream of income. Key benefits are tax deferral, estate tax savings, maintaining family wealth, and providing retirement income.
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The document discusses the Deferred Sales Trust (DST) as a strategy for property owners to defer capital gains taxes when selling appreciated assets like real estate. The DST allows the seller to transfer ownership of the property to a trust in exchange for a promissory note, deferred the capital gains tax until payments on the note are received. The trust then sells the property and uses the proceeds to invest and make scheduled payments to the seller over time based on terms in the promissory note. This allows the seller to defer capital gains tax for years while maintaining access to the value of the property through the installment payments. Key benefits of a DST include tax deferral, estate tax benefits, maintaining family wealth, and providing retirement income
- The document discusses the Deferred Sales Trust (DST) as a way for property owners to defer capital gains taxes when selling appreciated assets like real estate or businesses.
- With a DST, the owner sells the property to a trust. The trust then pays the owner over time based on a payment contract rather than immediately. This allows the owner to defer capital gains taxes until payments are received.
- Benefits of a DST include tax deferral, potential estate tax benefits, maintaining family wealth by passing the trust principal to heirs, and providing estate liquidity by converting an illiquid asset into monthly payments.
- The document discusses the Deferred Sales Trust (DST) as a way for property owners to defer capital gains taxes when selling appreciated assets like real estate or businesses.
- With a DST, the owner sells the property to a trust. The trust then pays the owner over time based on a payment contract rather than immediately. This allows the owner to defer capital gains taxes until payments are received.
- Benefits of a DST include tax deferral, potential estate tax benefits, maintaining family wealth by passing the trust principal to heirs, and providing estate liquidity by converting an illiquid asset into monthly payments.
Similar to August 2016 - New Proposed Regulations Restricting Valuation Discounts for Family-Controlled Entities - JSW (20)
August 2016 - New Proposed Regulations Restricting Valuation Discounts for Family-Controlled Entities - JSW
1. Prepared by Oxford Financial Group, Ltd. Page 1 of 3 JWS/LEB08182016
By: Julia Weaver, J.D., Director, Family Office Services and
The Trust Company of Oxford
Kara Talbott, CPA/PFS, CFP®
, Senior Wealth Strategist
Scott Simmons, J.D., LL.M., Wealth Strategist
Highlights and Planning Considerations
On August 2, 2016, the Treasury Department issued its proposed regulations under
Section 2704 that, when and if finalized, could greatly alter the availability
of valuation discounts for family-controlled entities.
In our January, 2016, article, "Estate Planning Freeze and Squeeze Strategies", we
mentioned the Treasury had publicized its intentions to issue these restrictive
regulations. After months of silence, it finally released these long awaited
proposed regulations that are much more restrictive than originally anticipated.
The impact on many current and future estate planning strategies could be
significant and would greatly impair the ability to receive valuation discounts on
interests in a family-controlled entity. This could potentially cause a significant
increase in some families federal estate exposure.
Several estate planning considerations should be assessed in determining the
proper course of action for each client's unique situation.
The current strategy of transferring discounted interests in a family-controlled entity
typically enables more overall wealth to be transferred to heirs, free of estate
taxation. By way of example, consider the following: Rather than passing only $10.9
million worth of actual value with the $10.9 million exemption (for 2016), it is far
better to pass $15.5 million of interest (reduced by a 30% valuation discount),
thereby “squeezing” more value through the $10.9 million exemption portal.
Simply put, less of the taxpayer’s gift and estate tax exemption is utilized when
transferring a discounted value of interest, leaving more exemption remaining to
apply to subsequent transfers. Valuation discounts also serve to potentially reduce
the taxable value of the estate.
Key Provisions in the Proposed Regulations
Immediate reactions to the proposed regulations include concerns that nearly all
minority and lack of control discounts could be disallowed in certain circumstances,
and that operating entities may be impacted as well as investment entities. The
following is a summary of five things you should initially know about these proposed
regulations.
1. Certain restrictions that previously resulted in valuation discounts on interest in
family-controlled entities would be disregarded when valuing a transferred
interest. This provision could cause the interest to be valued at a minimum value
which could potentially be the fair market value of the property held within the
entity, reduced only by outstanding obligations.
2. Certain transfers of interest in family-controlled entities occurring within three
years of the transferor's death would be treated as a lapse of voting and liq-
uidation rights occurring on the transferor's date of death. This would cause the
value of the reduction attributable to the minority status to be includible in the
gross estate.
Example – John gifts, after the regulations are finalized, 20% of the Family
Limited Partnership to each of his three children. John dies two years later.
The value reduction is brought back into John's estate.
3. Certain interests held by non-family members would be disregarded unless they
meet specific requirements.
The non-family member must have held the interest more than three years.
The interest must be more than 10% of the value of equity interest or capital
and profits interest.
The interest held when combined with other non-family interests must total
more than 20% of equity interest or capital and profits interest.
New Proposed Regulations Restricting Valuation Discounts for Family-Controlled Entities
August 2016 Issue WWW. OFGLTD.COM
2. Prepared by Oxford Financial Group, Ltd. Page 2 of 3 JWS/LEB08182016
The non-family member must have the right to "put" the interest to the entity
and be paid the minimum value as determined under the regulation, in cash or
other property, which cannot be a note issued by the entity, holders of interest in
the entity or a person related to the entity or any holder of interest in the entity.
In the case of an entity engaged in an active trade or business, if 60% or more of the
entity's value consists of non-passive assets of the trade or business and the
liquidation proceeds are not attributable to passive assets then proceeds may include
a note.
Families with operating businesses should discuss with legal and tax counsel to verify
that buy-sell agreements comply with the proposed regulations.
Example 1 – John and his brother's wife, Dana, own an active business equally.
However the proposed regulations would treat them as family members forcing
John's estate at his death to value his business interest without regard to
discounts for lack of control.
Example 2 – John, Bill and Susan are not related by blood or marriage. Each own
1/3 of an active business. Their buy/sell agreement calls for the entity to
repurchase a deceased owner's interest and issue a promissory note over a five
year period. They executed this agreement in order to allow for the continued
viability of their business without burdening its cash flow. They should consult
with legal and tax counsel to determine if their entity value and assets comply
with the regulation as finalized. If not, it is possible that no lack of control
discount would be available for their 1/3 interest at their death.
4. Also potentially disregarded would be certain restrictions created by transfers to
an assignee rather than a partner, as well as certain restrictions that are imposed by
state law.
5. The proposed regulations contain very broad family attribution rules, further
impacting the use of closely held entities as a planning strategy for minimizing estate
and gift taxes.
Control of an entity is defined as having at least 50% of the equity or capital and
profits interest. It would also include any equity interest held with the ability to cause
a full or partial liquidation. For determining control, interests held by members of the
transferor's family, defined as the transferor's spouse as well as the transferor's
ancestors, descendants, siblings and the spouses of all listed, are included in
determining control.
It is important to note that the proposed regulations are not effective immediately.
They will be effective after they have been adopted as final regulations. A public
hearing has been scheduled for December 1, 2016, suggesting that December will be
the earliest the new regulations would become effective.
Planning Considerations: Absence of Federal Estate Tax Exposure
Ironically, for many taxpayers the best planning strategy may be to simply do nothing
at all. As we highlighted in our July article, "Income Tax Planning with Family Entities
- The Quest for Basis Step-Up", many families have been relieved of exposure to the
federal estate tax due to the increasing exemptions amounts since 2002.
As we stated, "[t]he focus for these families is squarely upon income tax planning [and
the ability to obtain] a step-up in basis to the asset's fair market value on the date of
death. Consequently, when the value of an asset is reduced by valuation discounts,
the basis step-up potential is equally reduced... [S]hould heirs liquidate interest after
Senior's death, the heir must recognize that difference as gain for income tax
purposes."
In that article, we discussed strategies to eliminate valuation discounts in these
certain circumstances. The Service, however, may have just provided the ideal
mechanism to accomplish this strategy, to wit: do nothing at all.
Planning Considerations: Clear and Present Danger of Federal Estate Tax
For families where federal estate tax remains an ongoing threat to their legacy
wealth, there are certain planning strategies that may be considered in light of this
potential change in current laws. As always, any such strategies should be thoroughly
discussed with legal and tax counsel.
In some respects, currently discounted family-controlled entity interest is somewhat
akin to an appreciating asset. Once the regulations become final, the discounts may
fall off, resulting in a rapid increase in the value of the interest. Various planning
techniques may be structured so that this increase in value occurs outside of the
taxable gross estate, thereby avoiding the 40% federal estate tax on the increase in
value.
Such strategies may include sales to Intentionally Defective Grantor Trusts ("IDGTs") or
Grantor Retained Annuity Trusts (GRATs), as well as some asset titling opportunities,
all of which should be thoughtfully analyzed for each taxpayer's individual situation.
Additionally, the loss of discounts may cause a significant increase in a taxpayer's
federal estate tax exposure. Taxpayers should consider having their federal estate tax
analysis updated, along with a liquidity analysis for payment of any increased tax
obligations.
Caveats and Cautions
As with any estate planning strategy, caution must be exercised to avoid structuring
any potentially abusive transactions, including a transaction considered to have
pre-planned "steps" to achieve tax avoidance. A good estate planning attorney should
review any strategy so as to avoid this “step-transaction” doctrine, wherein the entire
strategy would be collapsed.
Additionally, the proposed regulations contain a potential three (3) year claw-back
period wherein any transfers made within 3 years of the transferor’s death could be
3. Prepared by Oxford Financial Group, Ltd. Page 3 of 3 JWS/LEB08182016
treated as a lapse causing inclusion in the gross estate of the value of the reduction of
the transferor’s interest attributable to certain previous discounts.
Next Steps
As discussed, there are vastly differing strategies for each taxpayer's specific situation
particularly depending upon whether there is current or anticipated federal estate tax
exposure. Along with coordinating the appropriate legal and tax review of the issues
discussed above, your Oxford advisors can assist with determining the proper course
of action for each client's unique situation.
*The Federal Estate Tax Exemption for 2016 is $5.45 million per person/$10.9 million per married couples,
above which all wealth is taxed at the rate of 40% upon any non-marital transfer.