Estate Taxation

  • A Tale of Three Freezes

    By:
    N. Todd Angkatavanich, JD, LLM (taxation) and Jonathan A. Mayer, CPA
    |
    Aug 1, 2018
    As a general proposition, all estate freeze transactions share some common characteristics. These transactions generally involve a senior generation family member (sometimes referred to as "Senior Family Member") making some form of a transfer of an asset and receiving back some form of cash-flow interest (e.g., a promissory note, a fixed annuity interest, or a preferred payment). 
  • U.S. Taxation of U.S. LLCs: Major Considerations in the International Context

    By:
    Michael W. Galligan
    |
    Jul 1, 2018
    Many countries make a strict distinction between corporations and partnerships for tax purposes and do not have a “check-the-box” election or, if they do, it does not necessarily follow the U.S. scheme. 
  • Both Sides Now: The Increasing Importance of Focusing on Both Sides of Competence for Families and Family Owned Enterprises

    By:
    Patricia Annino, Esq., JD, LLM (taxation)
    |
    Jul 1, 2018

    We are in a global societal phase change and are living in a non-linear world. All of us know someone who is one year old, and most of us know individuals who are older than 100. Many generations now coexist—entwining families emotionally, intellectually, physically, and financially in unprecedented ways. Accountants have never been in the position of planning for and impacting so many generations at once.

  • How Will the Trump Administration Impact Estate Taxes and Medicaid Benefits for Long-Term Care?

    By:
    Anthony J. Enea, Esq.
    |
    Dec 1, 2017
    While it still remains to be seen which specific legislative policies the Trump administration will enact, a repeal of the federal estate tax may be very likely if Congress passes tax reform or tax cuts.  
  • Key Tax Issues in Negotiating M&A Deals for Small Businesses

    By:
    Jordan L. Fieldstein, JD, LLM (taxation) and Michael P. Spiro, JD, LLM (taxation)
    |
    Oct 1, 2017
    Negotiating the sale of a small business begins with striking the commercial bargain between the parties. The alternative tax structures available to effect a single transaction, however, can have a significant impact on the parties’ economic bargain. 
  • Taxing Times for Non-Doms Post-Brexit

    By:
    Nick Warr
    |
    Aug 1, 2017
    Against the backdrop of Brexit, increasing economic uncertainty, and the rather strange political environment after the United Kingdom’s recent general election, it is rather surprising that on July 13, 2017, Theresa May's government announced its intent to push ahead with the proposed changes to the beneficial tax regime, which applies to U.K. residents but non-domiciled individuals (“non-doms”). 

  • Transfer of a Primary Residence: The Tax and Long-Term Care Consequences

    By:
    Anthony J. Enea, Esq.
    |
    Aug 1, 2017
    A senior citizen’s decision to transfer a primary residence raises a number of important issues for both the attorney and client—for example, gift taxes, potential capital gains tax consequences, and of course the transfer’s impact on the Medicaid eligibility of the senior. 
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