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The tax changes proposed by the “Unified Framework” for Tax Reform released on September 27, 2017 by the Trump Administration and Republican Congressional Leadership potentially affect the choice of entity in family business and investment structures. Under the current tax regime, passthrough entities (for example, LLCs or LPs taxed as ...

You’ve built a valuable and successful business through hard work, long hours and countless decisions. You want to plan for transitioning the company, and the wealth you’ve created to future generations, but you aren’t ready to cede control. As the company grows in value, the issue becomes acute. What do you do? You’re not a...

The White House joined Congressional Republican leaders in announcing a new framework for tax reform, which they hope to enact before the end of 2017. The framework provides much greater detail than the Trump Administration’s last several statements on possible tax reforms. Most of the changes—including major changes to tax rates and ne...

Many powerful trends are taking place in 2017. While much is still unknown in regard to what actions the new Trump administration and GOP-led congress will take towards the estate tax, planners have many opportunities to provide clients structures for both the short and long term. Additionally, planners will need to continue to factor in the recent...

Trusts have grown enormously in popularity since the mid-1990s as a result of the development of modern trust laws, the dramatic increase in wealth and evolving family needs and goals. Modern trust laws promote many key desires of a family’s estate planning, such as flexibility, control, tax savings, asset protection, family values, governanc...

The Trump Administration recently released its "Unified Framework for Fixing our Broken Tax Code" to flush out its tax reform priorities for individuals and businesses. The nine-page document is similar to the single-page bulleted outline the Administration rolled out in April, and it reiterated its position that taxes on corporations and...

New tax regulations from the Internal Revenue Service should have companies reviewing their business aircraft ownership structure and operations, according to a report from the law firm Wiley Rein. Depending on how this structure is set up, companies may find themselves subject to federal excise taxes on air transportation beginning January 1.

Taxing bodies in the UK and the United States are taking a closer look at debt-related strategies by hedge funds that are now tax exempt. And as investment strategies become more diverse, this interest by fiscal authorities can only be expected to increase. This paper from PricewaterhouseCoopers explores the potential ramifications for global hedge...

A health and education exclusion trust may offer a way to preserve assets for younger family members and avoid harsh generation-skipping taxes, while still contributing to charity. In this article, Mela Garber of Anchin, Block and Anchin explains how a HEET can be a useful and effective estate planning tool that benefits family and a designated cha...

By thinking ahead and paying a long-term capital gain today, an investor can derive a net tax benefit in future years. This research brief from Parametric Portfolio Associates explores the tax-management strategy of realizing such gains in a portfolio of equities and quantifies how much this can add to after-tax performance. The authors evaluate th...

This paper will examine ways to lessen six of the greatest risks to preserving and enjoying multigenerational wealth. These six risks are: concentrating your assets, overspending, overusing leverage, poor tax planning, not attending to liabilities, ignoring family governance

Two notices from Withers Worldwide discuss changes to U.S. tax rules in the deferred remuneration area that take effect on 1 January 2009. These rules (found in Sections 409A and 457A of the U.S. tax code) target deferred payments that do not satisfy complex technical requirements, imposing a compliance burden on non-U.S. as well as U.S. employers....

A limited liability company may seem like the best way to structure private aircraft ownership, organizing finances while shielding other assets from liability, but think again, says Gary Horowitz of Wiley Rein. Using an LLC can lead to a huge tax liability, potential fines by the Federal Aviation Administration and increased personal liability. Th...

With short-term interest rates currently near zero, this may be a good time to consider using intra-family loans, grantor retained annuity trusts and sales to intentionally defective grantor trusts.

By limiting the deductibility of investment-managing expenses by trusts, the Supreme Court's decision in the Knight case increases the taxes on trusts that use professional investment managers. This article by Richard LeVine of Withers Bergman examines the ruling and notes the need for innovative relationships between trusts and assets managers to ...