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Latest Updates

  1. Dodd-Frank Wall Street Reform and Consumer Protection Act
  2. Congress has made a policy decision to stage the effectiveness of the law over time, giving financial institutions and other market participants the ability to prepare.
  3. Codification of the Economic Substance Doctrine
  4. Taxpayers may properly structure any legitimate transaction in order to save taxes, provided that any transaction is in fact what it appears to be in form.
  5. What Split-interest Strategies Make Sense in a Low Interest Rate Economy?
  6. There are proposals in Congress to require a minimum term of ten years for a GRAT. Individuals inclined to utilize a GRAT ought proceed immediately before the window of opportunity closes.
  7. Waiver of the 60-Day Tax-free Rollover Requirement
  8. Does the accumulated experience of rollover waiver letters give us any basis for predicting how likely a particular client’s request is to be approved?
  9. Planning Early to Lessen the 3.8% Medicare Tax on Investment Income
  10. Because higher income taxes and capital gains taxes may be just around the corner, reducing the 3.8% tax takes on hightened importance.
  11. Reprising Ralph
  12. Will the cumulative premiums paid under a term contract constitute a basis in such a contract that may be carried over as the initial basis of the new universal life contract received in exchange for the term contract?
  13. What Planners Need to Know to Cope with the Coming Retirement Wave
  14. For many, it is already too late. Millions simply do not have sources of income sufficient to enable them to retire comfortably, or at all.
  15. Are Annuities Right for Your Clients
  16. As the baby boom generation continues to age and the American economy continues to undergo structural change, planners need to be aware of the implications even when their clients refuse to be.
  17. States Fix Formula Clause Problem Created by Temporary Estate Tax Repeal
  18. If the words and concepts used in a formula to define the size of a bequest are no longer part of the Internal Revenue Code, do they have any meaning in interpreting and administering the estate?
  19. Deductions for Life Insurance Premium Payments to Welfare Benefit Plan Denied
  20. In recent years welfare benefit funds have been used as vehicles in tax-abusive schemes to generate current employer deductions for contributions that in reality are funding disguised deferred compensation arrangements.
  21. Domestic Asset Protection Trusts: New Chart Ranks the States
  22. Many estate and asset protection planners are using DAPTs to make some of their clients’ assets look unreachable to potential creditors. The choice of jurisdiction can have a significant effect on the timing and degree of protection.
  23. US Senate Budget Committee Resolution Provides Two-Year Extension of 2009 Estate Tax Levels
  24. Congress will continue to face enormous pressure to act on estate tax legislation this year.
  25. A Guide to Retirement Plan Fees & Expenses
  26. Surveys retirement plan fees and expenses to assist plan sponsors in achieving a greater understanding of their plan operations.
  27. Making Sure a Bequest Benefits the Intended Recipient
  28. Clients drafting a will should be aware of the financial health of those receiving their assets. If not, they could face the situation in which assets that they worked hard to acquire could be taken from the intended beneficiary to pay creditors.
  29. Estate Planning Lessons From Michael Jackson`s Death
  30. As we all know, Michael Jackson died last summer. Although the stories of his unusual lifestyle and abuses have flooded the media, it appears that his estate plan was rather conventional. But there are some important lessons to be learned.
  31. Activity in Parallel Universe Reveals Vast Untapped Market for Life Insurance on Earth
  32. Since the subject involves a vast untapped market for life insurance, through which a family can effectively achieve a second step-up in basis of property passing at death, it warrants a careful analysis.
  33. New Law Revamps Health Care Delivery System
  34. The new law revamps the nation’s health care system and includes more than $400 billion in revenue raisers and new taxes on employers and individuals.
  35. Life Insurance Valuation
  36. Reviews the circumstances in which life insurance valuation is called for, and the various measures that are used.
  37. Termination of Policy Subject to Loan Triggered Taxable Income
  38. Financial advisors should be sure that clients understand the potential tax consequences when loan-encumbered policies lapse, or are surrendered or terminated.
  39. Estate Planning For Families With A Special Needs Child
  40. The parents of a special needs child are faced with a unique estate planning challenge.
  41. Inherited IRA Held Exempt from Bankruptcy Estate under Federal Exemption
  42. This is a significant case in which inherited IRA assets are protected from creditor attachment under bankruptcy.
  43. The Transfer for Value Tax Trap
  44. As a general principle, the proceeds of a life insurance policy paid by reason of the insured`s death are exempt from federal income tax. The transfer for value rule is an exception to this general principle and is discussed in this article.
  45. High Net Worth Clients: How to Find Them, How to Service Them
  46. Here, as always, knowledge is power. For prospecting HNWs, the first thing to know is where and how to find them, so that is where we begin. However, once you`ve found them the key thing is to know their psychology.
  47. Estate Planning in Uncertain Times
  48. The definitive guide to advanced estate planning in uncertain times.
  49. Failure to Use Inside Procedure Spoils 1035 Exchange
  50. The transaction was not characterized as a 1035 exchange because there was no direct exchange or assignment of the original contract.
  51. The Will Approach
  52. The will approach is based upon one of two major assumptions. At the time of the interview, either the prospect has a will or doesn`t - there`s no middle ground.
  53. Do Not Pitch
  54. HNWs have been hit on so often that their first reaction to any financial advisor is mistrust. Your mission is to overcome that mistrust. How do you do it?
  55. Liberalized IRA to Roth IRA Conversion Rules in 2010
  56. Certain high income clients who have not previously made deductible IRA contributions ought consider opening a traditional IRA this year and contributing the largest allowable nondeductible contribution they can manage.

Current Comment



August 2010

Dodd-Frank Wall Street Reform and Consumer Protection Act (CC 10-35)

July 2010

Codification of the Economic Substance Doctrine (CC 10-31)

What Split-interest Strategies Make Sense in a Low Interest Rate Economy? (CC 10-32)

Waiver of the 60-Day Tax-free Rollover Requirement (CC 10-33)

The Key Executive Insurance Story (CC 10-34)

June 2010

Planning Early to Lessen the 3.8% Medicare Tax on Investment Income (CC 10-24)

Reprising Ralph (CC 10-25)

What Planners Need to Know to Cope with the Coming Retirement Wave (CC 10-26)

Are Annuities Right for Your Clients (CC 10-27)

States Fix Formula Clause Problem Created by Temporary Estate Tax Repeal (CC 10-28)

Deductions for Life Insurance Premium Payments to Welfare Benefit Plan Denied (CC 10-29)

Domestic Asset Protection Trusts: New Chart Ranks the States (CC 10-30)

May 2010

US Senate Budget Committee Resolution Provides Two-Year Extension of 2009 Estate Tax Levels (CC 10-19)

A Guide to Retirement Plan Fees & Expenses(CC 10-20)

Making Sure a Bequest Benefits the Intended Recipient (CC 10-21)

Activity in Parallel Universe Reveals Vast Untapped Market for Life Insurance on Earth (CC 10-22)

Estate Planning Lessons From Michael Jackson`s Death (CC 10-23)

April 2010

New Law Revamps Health Delivery System (CC 10-14)

Changes Affecting Individuals in the 2010 Health Reform Law (CC 10-15)

Changes Affecting Business in the 2010 Health Reform Law (CC 10-16)

Changes Affecting Large Employers in the 2010 Health Reform Law (CC 10-17)

New Medicare Taxes for High-Income Taxpayers (CC 10-18)

March 2010

Life Insurance Valuation (CC 10-09)

Termination of Policy Subject to Loan Triggered Taxable Income (CC 10 - 10)

Estate Planning For Families With A Special Needs Child (CC 10-11)

Inherited IRA Held Exempt from Bankruptcy Estate under Federal Exemption (CC 10-12)

HIRE Provides Immediate Payroll Tax Holiday (CC 10-13)

February 2010

The Transfer for Value Tax Trap (CC 10-06)

High Net Worth Clients: How to Find Them, How to Service Them (CC 10-07)

Estate Planning in Uncertain Times (CC 10-08)

January 2010

The 2009 Top 40 (CC 10-01)

Estate Tax Chaos (CC 10-02)

Failure to Use Inside Procedure Spoils 1035 Exchange (CC 10-03)

Book Review - A Practical Guide to Estate Planning For a Family with a Special Needs Child (With Sample Forms and Checklists) (CC 10-04)

Notice 2010-06 Offers Guidance on Correcting Document Failures Under Section 409A (CC 10-05)

December 2009

The Estate Planning Process (CC 09-52)

Don`t Overlook NUA Tax Break on Lump Sum Distributions of Employer Stock (CC 09-53)

House Passes Permanent Estate Tax Relief (CC 09-54)

Lapse of the Estate and GST Taxes in 2010? — FAQs (CC 09-55)

November 2009

Professional Alliances (CC 09-46)

Pension Plan COLAs for 2010 (CC 09-47)

Income Tax COLAs for 2010 (CC 09-48)

The Will Approach (CC 09-49)

Don`t Pitch (CC 09-50)

Liberalized IRA to Roth IRA Conversion Rules in 2010 (CC 09-51)

October 2009

Roth IRA Recharacterization Deadline Quickly Approaching (CC 09-41)

The Year End Review (CC 09-42)

Notice 2009-82 Special Rollover Relief (CC 09-43)

U.S. Estate and Gift Tax Consequences for Non-U.S. Citizens (CC 09-44)

Four Fourth Quarter Sales Boosters (CC 09-45)

September 2009

Two Tax Doctrines: Constructive Receipt and Economic Benefit (CC 09-36)

Fully Insured Plans (CC 09-37)

IRS Issues Three Revenue Rulings and Four Notices Affecting Retirement Plans (CC 09-38)

Book Review - Buy-Sell Agreements: Ticking Time Bombs or Reasonable Resolutions? (CC 09-39)

HSA Employer Comparable Contributions (CC 09-40)

August 2009

Coordinating Retirement Accounts with Estate Planning (CC 09-33)

Finding Income in Hard Times (CC 09-34)

Are Target-Date Funds Failing (CC 09-35)

July 2009

Trust Owned Annuities and the Non-Natural Person Rule (CC 09-29)

Notice 2009-27: Post-ARRA 2009 COBRA Guidance (CC 09-30)

The Year End Push is Here (CC 09-31)

The Spendthrift Clause (CC 09-32)

June 2009

Notice 2009-48 Provides Guidance on §101(j) EOLI Rules (CC 09-25)

New Section 7520 Valuation Tables (CC 09-26)

Expiration of Policy Subject to Loan Triggered Taxable Income (CC 09-27)

Don`t Overlook Beneficiary Designations and Settlement Options (CC 09-28)

May 2009

Should the Basis of a Life Contract be Adjusted by Mortality Charges? Rev. Rul. 2009-13 Says Yes in Context of Life Settlements; Certain Amounts over Adjusted Basis Treated as Capital Gains (CC 09-19)

GST Tax Planning: The Key Question to Ask a Middle Generation Prospect (CC 09-20)

Rev. Rul. 2009-14: Income Tax Guidance for Life Settlement Companies (CC 09-21)

Acquirers and Inheritors Dilemma: Discovering Life Purpose and Building Personal Identity in the Presence of Wealth (CC 09-22)

Tax Proposals Target Estate and Gift Tax Valuation Discounts (CC 09-23)

Tax Proposals Affecting Life Policies (CC 09-24)

April 2009

Saving for College: State-Run Plans vs. Effective Estate Planning (CC 09-14)

Your Client`s Buy-Sell Agreement: Ticking Time Bomb or Reasonable Resolution? (CC 09-15)

IRS Issues Ponzi Scheme Guidance (CC 09-16)

Know the Ins and Outs of 1035 Exchanges? (CC 09-18)

March 2009

Business Succession Planning That Meets the Owner`s Needs (CC 09-09)

Possible Tax Trap when Trustee of ILIT Disclaims Responsibility for Selection of Insurance Product (CC 09-10)

Tax Rules Governing Gifts: 2 Points on Donative Intent (CC 09-12)

February 2009

Termination of Policy Subject to Loan Triggered Taxable Income (CC 09-05)

Crummey Review (CC 09-06)

Rollovers of IRAs to Qualified Plans: An Overlooked Source of Planning Possibilities (CC 09–07)

American Recovery and Reinvestment Act of 2009 (CC 09–08)

January 2009

Top 50 Docs Viewed in 2008 (CC 09-01)

The Check is in the Mail (CC 09-02)

To the Moon, Alice!—How to Prospect Even Though People Are Fed Up with Marketing (CC 09-03)

Beware of the Code §2036 Tax Trap (and its Application to Crummey Trusts) (CC 09-04)

December 2008

Worker, Retiree, and Employer Recovery Act of 2008 Waives RMDs for 2009 (CC 08-46)

Market Declines and IRAs (CC 08-47)

Obama and the Estate Tax (CC 08-48)

Notice 2008-113 Clarifies Rules on 409A Corrections (CC 08-50)

Last Minute Charitable Contributions (CC 08-51)

November 2008

Economic Downturns and Estate Planning (CC 08-41)

The Heart of an Estate Plan (CC 08-42)

Tax Evasion v. Tax Avoidance (CC 08-43)

Final Regs Issued on EOLI Reporting Requirements (CC 08-44)

October 2008

Passing It on from the Inside Out (CC 08-37)

President Signs the Emergency Economic Stabilization Act of 2008 (CC 08-38)

Bill, "Boot" and 1035 Exchanges (CC 08-39)

Pension Plan Limitations for 2009 (CC 08-40)

September 2008

The Del Boca Vista Widow (CC 08-33)

Fifty-one Flowers: Current Perpetuities Law in the States (CC 08-34)

The Transferor`s Basis Exception to the Transfer For Value Rule (CC 08-35)

Limited Tax Credit for Certain Homebuyers (CC 08-36)

August 2008

Charitable Gifts Of Life Insurance - Part I (CC 08-29)

Charitable Gifts Of Life Insurance; Planning Ideas - Part II (CC 08-30)

IRS Issues Final Regs for Valuation of Annuity Contracts in Roth IRA Conversions (CC 08-31)

July 2008

The Just Enough Funding Technique: An Innovative New Strategy (CC 08-25)

Cancellation of Policy Subject to Loan Can Generate Taxable Income (CC 08-26)

U.S. Estate and Gift Tax Consequences for Non-U.S. Citizens (CC 08-27)

Long-Term Care Insurance—A Desirable, Tax-Advantaged Employee Benefit (CC 08-28)

First Half of 2008 - The 25 Most Viewed Docs (CC 08-29)

June 2008

Practical Succession Planning for the Family-Owned Business (CC 08-22)

Power of Appointment for Future Flexibility (CC 08-23)

May 2008

Split Dollar Life Insurance Funding: You Mean People Still Do That? (CC 08-18)

The Law of Intestacy (CC 08-20)

April 2008

Rights Of Creditors In Insurance (CC 08-14)

Notice 2008-30 Provides Guidance on PPA 2006 Distribution-Related Provisions (CC 08-15)

Supreme Court Opens Door to Breach of Fiduciary Duty Claims Against Administrators of Defined Contribution Pension Plans for Individual Account Losses (CC 08-16)

Modification of Split-Dollar Arrangement Not a Material Change to Underlying Life Insurance Contract (CC 08-17)

March 2008

Knight v. Commissioner - U.S. Supreme Court Rules On Important Issue Regarding Income Taxation of Trusts (CC 08-10)

The Effect of Divorce on Life Insurance Beneficiary Designations (CC 08-11)

Minors as IRA Beneficiaries: Help Your Clients Do It Right (CC 08-12)

Rev Proc 2008-24 Finalizes Guidance on Partial Exchanges (CC 08-13)

February 2008

Recent Case Spotlights Investor Initiated SOLI and the Insurable Interest Rule (CC 08-05)

2008 Brings a Zero Tax Rate on Portions of Investment Income (CC 08-06)

Hedging Estate Tax Uncertainty with ILITs (CC 08-07)

President Signs Economic Stimulus Act (CC 08-09)

January 2008

Tax Considerations in Gifts to Minors (CC 08-01)

Incentive Trusts (CC 08-02)

Estate Planning for Pets (CC 08-03)

The Leveraged Family Business CLAT (CC 08-04)

December 2007

A Pre-Holiday Gift from the IRS: NQDC Planning for 2007 and Beyond (CC 07-57)

Missing the Target? (CC 07-59)

Notice 2007-100 Allows 409A Corrections (CC 07-60)

Top 50 Docs Viewed in 2007 (CC 07-61)

November 2007

Dynastic Wealth Transfer (CC 07-53)

Book Review - A Practical Guide to Drafting Irrevocable Life Insurance Trusts (CC 07-54)

Estate Planning Strategies Designed for the C Corporation (CC 07-55)

Temporary Regs Issued on EOLI Reporting Requirements (CC 07-56)

October 2007

Using Annuities for Long-Term Care Planning (CC 07 - 45)

Modification of Irrevocable Trusts and State Law (CC 07 - 46)

New IRS Pronouncements on 419 Plans (CC 07 - 47)

2008 Inflation Adjustments (CC 07 - 48)

IRS Announces Pension Plan Limitations for 2008 (CC 07 - 49)

Transition Relief for Compliance with Final 409A Regulations Extended to January 1, 2009 (CC 07 - 50)

September 2007

To Convert or Not to Convert, That is the Question (CC 07-40)

Using QPRTs to Maximum Advantage for Wealthy Clients (CC 07-41)

Documentation Deadline for 409A Compliance is Extended and Additional Guidance is Issued (CC 07 - 43)

August 2007

Treasury, IRS Issue Final 403(b) Regulations (CC 07-35)

Annuity Traps for the Unwary (CC 07-36)

17 Advantages of a Will (CC 07-37)

Charitable IRA Gifts in 2007 (CC 07-39)

July 2007

Deferred Compensation (07-30)

New Rules Concerning Employer-Owned Life Insurance Affect Buy-Sell Agreements (With Sample Buy-Sell Provision) (07-31)

Ralphs Term Look-A-Like UL (07-32)

First Half of 2007 - The 20 Most Viewed Docs (CC 07-33)

June 2007

Rollover Deemed Valid Even Though Effectuated by Surviving Spouse (CC 07-27)

Small Business Tax Act Extends Kiddie Tax to Full Time Students up to Age 23 (CC 07-28)

Trustee-to-Trustee Transfers Constituted a Modification to a Series of Substantially Equal Periodic Payments (CC 07-29)

May 2007

Will the Real Mean Please Stand Up: Properly Calculating Investment Returns (CC 07-22)

Life Insurance: The Key to Success in Wealth Transfer Tax Planning (CC 07-23)

April 2007

Federal Taxation of Life Settlement Proceeds: A Question of Gain (CC 07-14)

Estate Planning for Blended Families (CC 07-16)

IRS Issues Final Section 409A Regulations (CC 07-17)

Notice 2007-34 Explains Application of Section 409A to Split-dollar Life Insurance Arrangements (CC 07-18)

Final 415 Regs Provide Comprehensive Guidance on Qualified Plan Benefit and Contribution Limits (CC 07-19)

March 2007

Estate Planning for Persons With Less Than $5 Million (CC 07-10)

Notice 2007-7 Provides Rules for Nonspousal IRA Rollovers (CC 07-11)

Update on State Death Tax Laws (CC 07-12)

8th Circuit Affirms IRS Section 2036 Attack Against FLP (CC 07-13)

February 2007

The Inheritor`s Trust (CC 07-07)

Revenue Ruling Details Transfer for Value Implications of Policy Transfer to Grantor Trust (CC 07-08)

Notice 2007-22 Explains Rollovers from Health FSAs and HRAs to HSAs (CC 07-09)

January 2007

NAIC Committee Approves Amendments to Viatical Settlements Model Act (CC 07-01)

IRS Modifies MEC Correction Mechanism in Rev. Proc. 2007-19 (CC 07-04)

IRS Issues Guidance on Distributions from IRAs to Charitable Organizations (CC 07-05)

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