IRS Tax Practice Unit: Receipt of Dividends or Interest from a Related CFC (July 29, 2020)

The IRS Large Business and International (LB&I) has issued a new Practice Unit, Receipt of Dividends or Interest from a Related CFC. Practice Units provide IRS staff with explanations of general tax concepts, as well as information on specific types of transactions. Practice Units are not official pronouncements of law or directives and cannot be … Continue reading IRS Tax Practice Unit: Receipt of Dividends or Interest from a Related CFC (July 29, 2020)

Bridgewater YouTube Video: Grappling with the New Reality of Zero Bond Yields Virtually Everywhere (July 23, 2020)

Bridgewater has released a video by Bridgewater Senior Portfolio Strategist, Jim Haskell, on managing money in a zero interest rate environment. The summary and video are below: We believe the most important topic facing all investors today is how to manage money in a zero interest rate environment. Recently, Bridgewater’s research team published a three-part … Continue reading Bridgewater YouTube Video: Grappling with the New Reality of Zero Bond Yields Virtually Everywhere (July 23, 2020)

Emily Taylor Poppe, Surprised by the Inevitable: A National Survey of Estate Planning Utilization (July 1, 2020)

Emily Taylor Poppe, of University of California, Irvine School of Law, has made available for download her article, Surprised by the Inevitable: A National Survey of Estate Planning Utilization, published in the UC Davis Law Review, Vol. 53, No. 5, 2020. The Abstract is as follows: The laws governing the transfer of property at death … Continue reading Emily Taylor Poppe, Surprised by the Inevitable: A National Survey of Estate Planning Utilization (July 1, 2020)

Foley Lardner: Introduction to Family Offices (July 23, 2020)

Foley Lardner has published a succinct primer on Family Offices. It begins as follows: What is a Family Office? A “Family Office” is a wealth management entity created to provide investment and wealth management services tailored to the specific needs of a high net worth (HNW) individual or familyA Family Office can take on many … Continue reading Foley Lardner: Introduction to Family Offices (July 23, 2020)

Paul Sullivan, Wealth Matters, NY Times (July 24, 2020): Need Help With Your Estate Plan? Go With the Flow, Advisers Say

Paul Sullivan's weekly New York Times Wealth Matters column focuses on the use of flowcharts and other visual aids in the context of estate planning. It begins as follows: As older adults face mortality during the pandemic, lawyers and wealth advisers are using color-coded documents and flowcharts to help them understand estate planning. To see … Continue reading Paul Sullivan, Wealth Matters, NY Times (July 24, 2020): Need Help With Your Estate Plan? Go With the Flow, Advisers Say

HBR – The Big Idea: The New Reality of Working From Home (WFH) – a Seven Part Series

Do We Really Need the Office?What the WFH boom means for the future.The Implications of Working Without an OfficeEarly research on how people are — and aren’t — adapting and how leaders can help.Microsoft Analyzed Data on Its Newly Remote WorkforceHere’s what it found about meetings, culture, workdays, and engagement. Building Work-Life Boundaries in the WFH … Continue reading HBR – The Big Idea: The New Reality of Working From Home (WFH) – a Seven Part Series

Belair Woods, LLC v Commissioner, TC Memo 2020-112 (July 22, 2020): Partnership Not Entitled to Charitable Contribution Deduction

The tax matters partner of a partnership was not entitled to a charitable contribution deduction because the conservation purpose underlying the easement was not protected in perpetuity as required by Code Sec. 170(h)(5)(A). See full opinion by clicking Belair Woods, LLC v Commissioner, TC Memo 2020-112 (July 22, 2020).

Michael Kitces, Kitces Report (July 22, 2020): Harvesting Capital Gains Vs Roth Conversions At 0% Tax Rates

Michael Kitces has written about Harvesting Capital Gains Vs Roth Conversions At 0% Tax Rates. The Executive Summary of his article is as follows: For many high-income clients, financial advisors recommend deferring income as a strategy to mitigate taxes, especially when the client is in a high tax bracket and expects to be in a … Continue reading Michael Kitces, Kitces Report (July 22, 2020): Harvesting Capital Gains Vs Roth Conversions At 0% Tax Rates

William Finestone (Blank Rome LLP): Low Interest Rate Gift Planning, Estate Planning Magazine (July 2020)

William Finestone, of Blank Rome, has made available for download his article, Low Interest Rate Gift Planning, published in Estate Planning Magazine (July 2020). The abstract is as follows: While clients still have all of 2020 to take advantage of annual exclusion gifts (currently $15,000 per donee) and the increased lifetime gift tax exemption (now … Continue reading William Finestone (Blank Rome LLP): Low Interest Rate Gift Planning, Estate Planning Magazine (July 2020)

Ray Dalio: The Changing World Order: The Big Cycle of the US and the Dollar, Parts 1 and 2 (July 21, 2020)

Ray Dalio has been publishing a series of detailed articles on The Changing World Order. The most recent parts are The Big Cycle of the US and the Dollar, Parts 1 and 2. The most recent part, Chapter 4: The Big Cycle of the United States and the Dollar, part 2, was published today and … Continue reading Ray Dalio: The Changing World Order: The Big Cycle of the US and the Dollar, Parts 1 and 2 (July 21, 2020)

Lily L. Batchelder, David Kamin: Policy Options for Taxing the Rich, Aspen Institute (2019)

Professors Lily L. Batchelder (NYU) & David Kamin (NYU) have made available their article, Policy Options for Taxing the Rich, published by the Aspen Institute (2019). The Abstract is as follows: The U.S. economy exhibits high inequality and low economic mobility across generations relative to other high-income countries. The United States will need to raise … Continue reading Lily L. Batchelder, David Kamin: Policy Options for Taxing the Rich, Aspen Institute (2019)

Jones Day: IRS to Begin Examination of High-Wealth Taxpayers (July 15, 2020)

Jones Day and several other sources have reported that the Internal Revenue Service ("IRS") announced that as soon as it reopens its collection and examination functions on July 15, it will immediately begin the examination of hundreds of high-income individuals and private foundations that are often established by high-income taxpayers through the Global High Wealth … Continue reading Jones Day: IRS to Begin Examination of High-Wealth Taxpayers (July 15, 2020)

IRS Practice Units Released On S Corp Distributions with Accumulated Earnings & Profits (July 14, 2020)

The IRS Large Business and International (LB&I) division has released a series of practice units for IRS agents, which are a resource on substantive topics for agents, on S corp distributions of accumulated earnings and profits. See the IRS Practice Units Below: Distributions with accumulated earnings & profitsGeneral overview of accumulated earnings & profits

Florida Probate & Trust Litigation Blog: Prenuptial agreement vs. revocable trust: who wins?

Juan C. Antunez, on his Florida Probate & Trust Litigation Blog writes about what happens when there is a conflict between a prenup and a revocable trust, by focusing on Wilson v. Wilson as Trustee of Paul C. Wilson Living Trust, — So.3d —-, 2019 WL 3808162 (Fla. 4th DCA August 14, 2019). His article … Continue reading Florida Probate & Trust Litigation Blog: Prenuptial agreement vs. revocable trust: who wins?

Bridgewater + Ray Dalio Videos: Impact of Pandemic on Economy: Impact on Markets and Economy and Potential Stagflation; Ray Dalio on Changes Needed to Capitalism

Bridgewater and Ray Dalio, founder of Bridgewater, have posted or participated in several online videos. They are as follows. Bloomberg: Co-CIO Bob Prince Discusses Impact of Pandemic on Markets and Global Economy June 24, 2020: As part of the Bloomberg Invest Global virtual summit, Co-CIO Bob Prince spoke with Jonathan Ferro of Bloomberg TV about … Continue reading Bridgewater + Ray Dalio Videos: Impact of Pandemic on Economy: Impact on Markets and Economy and Potential Stagflation; Ray Dalio on Changes Needed to Capitalism

IRS IR-2020-142: Taxpayers need to resume payments by July 15

The IRS reminds taxpayers who took advantage of the People First Initiative tax relief and did not make previously owed tax payments between March 25 to July 15 that they need to restart their payments. As the IRS continues to reopen its operations across the country, taxpayers who were in payment agreements and skipped any … Continue reading IRS IR-2020-142: Taxpayers need to resume payments by July 15

AICPA Tax Insider (June 11, 2020): student loan tax incentives; remote signatures; Notice 2020-23; and more

New tax incentive for employers to help with student loans By Dave Strausfeld, J.D. Employers can make tax-free contributions in 2020 to help employees with their student loan payments, under a provision in the CARES Act. Here's how. IRS permits remote signatures for plan loan consents In another response to the COVID-19 pandemic, the IRS … Continue reading AICPA Tax Insider (June 11, 2020): student loan tax incentives; remote signatures; Notice 2020-23; and more

Thomas P. Gallanis: Commercial Trusts in U.S. Legal Thought: Historical Puzzles and Future Directions

Thomas Gallanis has made available for download his article, Commercial Trusts in U.S. Legal Thought: Historical Puzzles and Future Directions.  The Abstract is as follows: The law of commercial trusts has been taught in universities in London and Cambridge, Sydney and Melbourne, Hong Kong and Singapore, but it is absent from the law schools of the … Continue reading Thomas P. Gallanis: Commercial Trusts in U.S. Legal Thought: Historical Puzzles and Future Directions

Treasury Secretary Steven T. Mnuchin and SBA Administrator Jovita Carranza Issue Joint Statement Re Enactment of the Paycheck Protection Program Flexibility Act

Treasury and SBA issued a joint statement re the Paycheck Protection Program Flexibility Act. The key portion of the statement addresses updated PPP procedures, which are as follows: SBA, in consultation with Treasury, will promptly issue rules and guidance, a modified borrower application form, and a modified loan forgiveness application implementing these legislative amendments to … Continue reading Treasury Secretary Steven T. Mnuchin and SBA Administrator Jovita Carranza Issue Joint Statement Re Enactment of the Paycheck Protection Program Flexibility Act

Lee-ford Tritt & Ryan Scott Teschner: The Rise of Business Trusts in Sustainable Neo-Innovative Economies

Lee-ford Tritt & Ryan Scott Teschner have made available for download their article, The Rise of Business Trusts in Sustainable Neo-Innovative Economies, published in the University of Cincinnati Law Review. The Abstract is as follows: Business trusts have been commonly used in the United States as an organizational form for over 100 years. Historically, entrepreneurs … Continue reading Lee-ford Tritt & Ryan Scott Teschner: The Rise of Business Trusts in Sustainable Neo-Innovative Economies