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COVID-19, unfortunately, is now among the examples of causes for the need to appoint a guardian... It is always advisable for individuals to express their own wishes regarding whom they want to manage their affairs if they become unable, which is traditionally done through a power of attorney. However, situations may arise when someone needs […]

In PLR 201725022, a corporation received rental income from its leasing of offices for medical and related services.  The taxpayer intended the rental income from its maintenance-related operations as non-passive investment income under section 1362(d)(3)(c)(i). In PLR 201725022, a corporation received rental income from its leasing of offices for medical and related services.  The taxpayer intended the rental […]

The government lost estate and gift tax cases that attracted headlines. The government lost estate and gift tax cases that attracted headlines. In response, the Department of Treasury (“Treasury”) proposed new regulations in early 2016 that would amend definitions in the 1992 regulations that were problematic in the court cases. In addition, Treasury it added […]

The U.S. tax system can be pretty complicated, especially for small businesses. The U.S. tax system can be pretty complicated, especially for small businesses. According to the Tax Foundation, enterprises across the nation spend 2.8 billion hours annually filing business income tax returns. This doesn’t include S Corporations, the employer’s quarterly federal tax return, sales […]

The IRS List of “Bad Banks” The IRS updated its list of “Bad Banks” last month, which is now up to 95 banking institutions. This list will continue to grow as Swiss banks and foreign financial institutions come under more intense scrutiny from the Department of Justice to force public disclosure. So if your client’s bank […]

Denial of Treaty Benefits and Limitation of Benefits One of the hallmarks of international tax planning is the ability to obtain a tax ruling from a foreign revenue services that the taxpayer is a qualified resident for income tax treaty purposes. Such a ruling permits a taxpayer to proceed with certainty in establishing operations. It […]

Will Spendthrift Language In A Trust Always Be Respected? The unequivocal answer to the question is: it depends. The grantor’s purpose for including spendthrift language in a trust is to protect the trust assets set from the beneficiary’s creditors and to prevent the beneficiary from selling or assigning his or her interest in the trust. […]

Are Roth IRAs more profitable for the taxpayer? Many taxpayers are wondering about the impact of the new IRS ruling on Roth IRA total annual contribution limits. According to a National Law Review report, on Oct. 21, the IRS ruling will create fewer limitations on after-tax contributions directly to Roth IRAs when a taxpayer retires, […]

New estate planning channel for older demographic? A recent decision by the U.S. Tax Court affirmed the estate planning opportunity for older individuals that was perceived by some as being safely available in the Fifth Circuit where the Tax Court’s McCord decision, that was adverse to the taxpayer, was reversed. According to a Law 360 […]

Substantial Compliance The state probate code was amended in 2004 to permit documents that were intended to have testamentary effect but were not executed in accordance with the statutory requirements. The new probate code’s doctrine of substantial compliance holds that if a document was not executed in compliance with the statute, the proponent may establish […]

The Ninth U.S. Circuit Court of Appeals recently ruled that unmarried individuals who purchased a home together are eligible to a home mortgage interest deduction for up to $1.1 million in debt each. This decision reversed a previous tax court decision that stated unmarried individuals were subject to the same $1.1 million limitation as married […]

Although all individuals holding a life insurance policy own an investment, they did not have the legal right to exert control over the investments inside the policy. However, according to a recent ruling by the U.S. Tax Court, investors who exercise control over how money is invested are subject to tax on the investment income. […]