With the passage of the Tax Cuts and Jobs Act at the end of 2017, more family businesses are examining their corporate structure and considering the tax implications. Specifically, companies that are currently structured as “pass-through” entities (e.g., an S corporation, partnership, or LLC taxed as an S corporation or partnership) are examining the new-found benefits of converting to a C-Corp.
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After a decade-long economic expansion and bull market in US stocks, investors are understandably nervous about downside risk. Global economic policy uncertainty rose sharply in 2018, fueled by the threat of a trade war among the world’s largest economies. With the stock market crash of 2008-’09 a distant but still painful memory, many investors are asking about efficient ways to protect their hard-won gains of the last decade. One of the primary tools that investors consider is the purchase of put options to protect their equity portfolios.
A GRAT is an estate freeze technique used in estate planning to minimize taxes on large financial gifts to family members. Under this technique, an irrevocable trust is created to which the grantor transfers income-producing or appreciating property in return for the right to receive a distribution of a fixed annuity amount from the trust (at least annually) for a specified term of years. GRATs have a few benefits, including the reduction of estate tax liability at death.
Following recent amendments to the tax code, both the applicable estate and gift tax exemption and the GST exemption were increased to $11,180,000. This nearly doubled the exemptions available in 2017. Taxpayers may consider making additional gifts to already existing dynasty trust in order to further supercharge the trust. They may also consider allocating GST exemption to an existing non-Dynasty Trust, to convert it into a Dynasty Trust that allows for a transferor to maximize the assets that are available to support future generations.
Investors are purchasing and selling virtual currencies (also known as “crypto currencies”) at a faster rate than ever before. Although these virtual currencies are not legal currency in the U.S., the IRS has been slowly issuing guidance on the income taxation and the manner in which individuals should report gains or losses from the sale or exchange of these currencies on their income tax returns.
The tax consequences of expatriation for U.S. citizens and long-term green card holders after June 17, 2008 can be enormous. With the exception of deferred compensation items, interests in non-grantor trusts, and specified tax deferred accounts, all other assets of the expatriating taxpayer are deemed sold at fair market value on the day before the expatriation dates. Although, an exemption is granted for the first $711,000 of deemed gain in 2018, this so called 'exit tax' is harsh on long-term green card holders who inadvertently lose their status.
Tax reform has necessitated a reevaluation of many individual’s estate plans. It significantly increased the ability of high-net-worth individuals and families to pass wealth free of estate, gift, and generation-skipping transfer (GST) taxes, while increasing the importance of income tax planning due to changes to income tax rates and brackets, as well as standard and itemized deductions.
The ability to attract, retain, and reward a superior workforce is fundamental to every organization’s long-term growth. One way to achieve it is to offer stock options to employees, giving them a stake in the company’s value as part of their compensation package. In general, there are two forms of stock options: nonqualified stock options and incentive stock options.
When an individual purchases property, inherits property, or is gifted property, they obtain a tax basis in the property. Basis is generally the amount of the taxpayer’s capital investment in the property, which is subsequently increased or decreased for events that occur during their ownership of the property.
The bond market often provides important clues about investor expectations that are harder to discern from the daily vacillations of stock prices. Today the jump in 10-year yields has widened the spread between 2’s and 10’s to 34 basis points, moving further away from the feared inverted yield curve condition. And based upon little change in the outlook for inflation, the bond market is now anticipating stronger, more sustainable growth in the economy than it had a month ago. If the economy is generating strong non-inflationary growth, why are stock investors flipping out?