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Estate Taxation

  • Estate Tax Planning for NRNCs Using the Foreign Corporation

    By:
    Gary A. Forster, JD, LLM
    |
    May 1, 2022
    Lifetime gifts of U.S. intangibles by non-resident non-citizens (NRNCs) are exempt from gift tax. However, all U.S. situs assets, both tangible and intangible (unless falling within a limited exemption), are subject to estate tax. Those same assets held in a foreign corporation are excluded from estate tax.
  • Five CAA Benefits Changes and their Tax-Exempt Entity Impact

    By:
    Daniel N. Kuperstein, Esq.
    |
    Apr 1, 2022
    Although extraordinarily helpful to benefit plan participants, the coronavirus (COVID-19) tax relief available under the Consolidated Appropriations Act, 2021 (CAA) has caused many headaches for CFOs and other managers of tax-exempt (TE) entities. These headaches have continued into 2022.
  • The Evolution of the Form 990-T

    By:
    Heather Leggiero, CPA, JD
    |
    Apr 1, 2022
    Over the past several years, Form 990-T, Exempt Organization Business Income Tax Return, has changed from its pre-2018 versions. The Taxpayer Cuts and Jobs Act of 2017 (TCJA) made significant changes to the unrelated business income (UBI) tax law and required years of revisions as guidance was issued by the IRS. Two major UBI TCJA changes were made to the net operating loss (NOL) rules and the introduction of siloing to segregate multiple unrelated trade or business activities.
  • Go With the Flow: Cash Flow Planning for Every Life Stage

    By:
    Jill A. Harris, CPA, MBA
    |
    Jan 1, 2022
    Cash flows are among the most basic components of personal financial planning. They are a great way to jump-start discussions with your clients about other financial planning issues. If you prepare individual income tax returns for your clients, you already have a good start on their cash flows.
  • Modern Asset Protection – An Introduction

    By:
    Gary Forster
    |
    Dec 1, 2021

    Asset protection is a body of law that has developed as an amalgamation of business structures, trusts, titling and creditor exemptions. Asset protection planning insulates assets otherwise exposed to future unknown creditors. Prudent structuring uses widely accepted legal strategies to make clients unattractive to claimants.

  • FLPs with Estate Plans

    By:
    Phyllis C. Taite, JD, LLM
    |
    Nov 1, 2021
    A family limited partnership (FLP), when constructed properly, is an excellent tool to protect and consolidate assets for management through one instrument. For asset protection, assets held by a FLP are not subject to an individual’s creditors; instead, a charging order is usually required to attach a limited partnership interest.
  • Gift Tax Return Tips

    By:
    Joy Matak, JD, LLM, Steven B. Gorin, CPA, Esq., CGMA, and Martin Shenkman, CPA, MBA, AEP, JD
    |
    Oct 1, 2021
    Gift tax returns appear to be seductively simple. Failure to file a gift tax return timely and disclose transactions “in such return, or in a statement attached to the return, in a manner adequate to apprise the Secretary of the nature of such item” in accordance with regulations that impose specific requirements for “adequate disclosure” can delay the tolling of the statute of limitations.

 
Views expressed in articles published in Tax Stringer are the authors' only and are not to be attributed to the publication, its editors, the NYSSCPA or FAE, or their directors, officers, or employees, unless expressly so stated. Articles contain information believed by the authors to be accurate, but the publisher, editors and authors are not engaged in redering legal, accounting or other professional services. If specific professional advice or assistance is required, the services of a competent professional should be sought.