Ted Dougherty and Lisa Sergi – Tax Planning Using the Constructive Sale Rules – When is a Constructive Sale not a Constructive Sale?

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Tax Planning Using the Constructive Sale Rules – When is a constructive sale not a constructive sale?

By Ted Dougherty and Lisa Sergi

Notwithstanding strong headwinds in the financial markets, a number of hedge funds are sitting on large unrealized gains in their portfolios. Concerns arising from the outcome of elections … Continue reading

Special Needs – Special Trusts Part. 2: Drafting Considerations & Trust Administration Considerations – Bernard A. Krooks

SPECIAL NEEDS – SPECIAL TRUSTS – WHAT YOU DON’T KNOW CAN HURT YOUR CLIENTS AND YOU!

Part. 2: Drafting Considerations & Trust Administration Considerations

By Bernard A. Krooks

Littman Krooks LLP New York, New York / www.littmankrooks.com

Part. 1 Overview & Taxation

III. Drafting Considerations

A. Trustee Selection

The selection of … Continue reading

Alexandre M. Denault & Jonathan E. Gopman – Treasury Department Extends Form 5472 Filing Requirements to Foreign-Owned Domestic Disregarded Entities

Treasury Department Extends Form 5472 Filing Requirements to Foreign-Owned Domestic Disregarded Entities

By: Alexandre M. Denault & Jonathan E. Gopman

On May 10, 2016, Treasury issued proposed regulations (the “Proposed Regulations“) which enable the Internal Revenue Service (the “Service“) to collect certain information about domestic disregarded … Continue reading

HERE COMES THE MOUNTAINAIR TRUST – WEST VIRGINIA PASSES ASSET PROTECTION TRUST LEGISLATION (EFFECTIVE JUNE 8, 2016)

WEST VIRGINIA PASSES ASSET PROTECTION TRUST – TRUST LEGISLATION EFFECTIVE JUNE 8, 2016  – HERE COMES THE MOUNTAINAIR TRUST

By Jonathan GopmanMichael Sneeringer and Alan Gassman

Almost haven,

West Virginia,

Advances its trust law,

Throwing future creditors in the river.

 

Trusts are old there,

Like the Confederacy,

Until Continue reading

Espen Robak and Richard L. Harris – Intergenerational Economic Benefit Split-Dollar Transaction Passes Crucial Test in Tax Court (Estate of Morrissette Wins First Round)

Intergenerational Economic Benefit Split-Dollar Transaction Passes Crucial Test in Tax Court

Estate of Morrissette Wins First Round

By Espen Robak and Richard L. Harris

Intergenerational[i] split-dollar transactions have become a popular way for families to purchase life insurance, and to do so in a tax efficient transaction structure that … Continue reading