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  1. Charitable Gifts Of Life Insurance - Part I
  2. The utilization of life insurance in plans for charitable giving can provide substantial tax benefits, while satisfying the taxpayer`s philanthropic inclinations and providing meaningful benefits to charitable organizations.
  3. Charitable Gifts Of Life Insurance; Planning Ideas - Part II
  4. Part II discusses planning ideas for prospective donors. Financial advisors who work with this market have often found a rich vein of new business.
  5. IRS Issues Final Regs for Valuation of Annuity Contracts in Roth IRA Conversions
  6. Among the most important considerations in deciding whether to convert a traditional IRA to a Roth IRA is the amount that is includible as a result of the conversion.
  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? Some situations are more favorable than others, and allow us to suggest some guidelines.
  9. U.S. Estate and Gift Tax Consequences for Non-U.S. Citizens
  10. A decedent who at the time of death was not a resident or citizen of the United States, may nonetheless be subject to U.S. estate tax if at the time of death he or she owned property in the United States.
  11. First Half of 2008 - The 25 Most Viewed Docs
  12. The 25 most viewed documents.
  13. Long-Term Care Insurance—A Desirable, Tax-Advantaged Employee Benefit
  14. With mass retirement looming for the baby boom generation just as their projected lifespans lengthen, employers are well advised from the human resources point of view to consider making long-term care (LTC) insurance available to their employees.
  15. The Just Enough Funding Technique: An Innovative New Strategy
  16. The just enough funding technique is designed to meet a married couples estate planning objective of funding a credit shelter trust at the death of the first spouse to die only to the extent necessary or desirable to avoid estate tax at the second death.
  17. Cancellation of Policy Subject to Loan Can Generate Taxable Income
  18. The Atwood case underscores the painful income tax consequences which can accompany the lapsing or cancellation of a life insurance policy whose cash value has previously been substantially depleted through policy loans.
  19. Power of Appointment for Future Flexibility
  20. Powers of appointment are a valuable tool in estate plans, because they allow for future flexibility in the ultimate disposition of the donors property which is placed in a trust.
  21. Summer Is A- Comin In...
  22. Take some time this summer to make an investment in yourself. Learning new skills and better ways to serve your clients demands a certain commitment of time and energy—but the payoff can be spectacular.
  23. Practical Succession Planning for the Family-Owned Business
  24. An effectively developed succession plan provides for a smooth transition in management and ownership with a minimum of transfer taxes.
  25. Certain Split-interest Strategies Helped By Current Low Interest Environment
  26. Why is it that the value of the remainder under a GRAT is less if the section 7520 rate is lower, and why is that a plus?
  27. Crummey Powers And The Code Section 2036 Tax Trap
  28. The discussion illustrates how easily a couple might fall into the 2036 tax trap, even while engaging in otherwise sophisticated tax saving estate planning techniques.
  29. Split Dollar Life Insurance Funding: You Mean People Still Do That?
  30. Despite the gloom and doom forecasted by many in the insurance industry and the legal profession, the final Regulations did not sound the death knell for split-dollar planning.
  31. Modification of Split-Dollar Arrangement Not a Material Change to Underlying Life Insurance Contract
  32. Notice 2008-42 provides guidance regarding the application of 101(j) EOLI rules and 264(f) to life insurance contracts that are subject to split-dollar arrangements.
  33. Notice 2008-30 Provides Guidance on PPA 2006 Distribution-Related Provisions.
  34. Notice 2008-30 provides guidance on distribution-related provisions of the Pension Protection Act of 2006 that are effective in 2008 including rollovers from eligible retirement plans to Roth IRAs.
  35. Supreme Court Opens Door to Breach of Fiduciary Duty Claims Against Plan Administrators for Individual Account Losses.
  36. The Court’s LaRue decision is a marked shift from its prior ruling that the ERISA provision concerning breach of fiduciary duties protects the entire plan, rather than the rights of an individual beneficiary.
  37. Rights Of Creditors In Insurance
  38. If there were no insurance exemption from the claims of creditors, the purpose for owning insurance would be undermined. The financial security of an insured`s dependents would depend upon whether the insured was solvent or insolvent at the time of death.
  39. Rev Proc 2008-24 Finalizes Guidance on Partial Exchanges
  40. What happens if only a portion of an existing annuity contract is exchanged for a new contract, while the balance of the original contract is retained? Is it a qualified exchange transaction under §1035?
  41. The Effect of Divorce on Life Insurance Beneficiary Designations
  42. Beneficiary designations are among the most important aspects of financial planning with life insurance. All too often, circumstances change but beneficiary designations do not, frustrating the policyholder`s post-death objectives.
  43. Minors as IRA Beneficiaries: Help Your Clients Do It Right
  44. Under common law minors cannot own property in their own names. This does not mean that a minor cannot inherit an IRA or be designated as the beneficiary of an IRA; it means that their are special considerations.
  45. Knight v. Commissioner - U.S. Supreme Court Rules On Important Issue Regarding Income Taxation of Trusts
  46. U.S. Supreme Court decisions relating to income tax are rare. Rarer still are Supreme Court decisions involving the income taxation of trusts. Knight resolves a significant controversy with important implications to trusts.
  47. President Signs Economic Stimulus Act
  48. On February 13 President Bush signed into law the Economic Stimulus Act of 2008, the highlight of which is the government`s issuance of rebate checks to more than 130 million Americans.
  49. Hedging Estate Tax Uncertainty with ILITs
  50. The unique characteristics of life insurance make an irrevocable life insurance trust a unique hedge against both tax uncertainty and the contingency of mortality.
  51. The Transfer for Value Tax Trap
  52. 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.
  53. Recent Case Spotlights Investor Initiated SOLI and the Insurable Interest Rule
  54. It would seem that if these transactions are to be invalidated by reason of the insurable-interest rule, the winner should be the insurance company.
  55. The Leveraged Family Business CLAT
  56. Learn about a technique that allows decedents to pass their closely held businesses to their beneficiaries through a testamentary CLAT.
  57. Life Insurance Delivers Reliable Tax Benefits
  58. The final sales push of the year is a good time to remind ourselves of the reliable and powerful tax benefits of life insurance.

Current Comment



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)

Waiver of the 60-Day Tax-free Rollover Requirement (CC 08-32)

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)

Summer Is A- Comin` In . . . (CC 08-24)

May 2008

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

Crummey Powers And The Code Section 2036 Tax Trap (CC 08-19)

The Law of Intestacy (CC 08-20)

What Split-interest Strategies Make Sense in a Low Interest Rate Economy? (CC 08-21)

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)

The Transfer for Value Tax Trap (CC 08-08)

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)

One of the Best Devices for Client Retention—The Year End Review (CC 07-58)

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

Life Insurance Delivers Reliable Tax Benefits (CC 07-51)

The Will Approach (CC 07-52)

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

Estate Planning For Families With A Special Needs Child (CC 07 - 44)

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)

Don`t Overlook Beneficiary Designations and Settlement Options (CC 07-42)

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)

Don`t Overlook NUA Tax Break on Lump Sum Distributions of Employer Stock (CC 07-38)

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)

Activity in Parallel Universe Reveals Vast Untapped Market for Life Insurance on Earth (CC 07-34)

June 2007

The Key Executive Insurance Story (CC 07-25)

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

Shielding Trust Beneficiaries from Creditors Through a Spendthrift Clause (CC 07-21)

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)

Failure to Use Inside Procedure Queers 1035 Exchange (CC 07-24)

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

Life Insurance Valuation (CC 07-06)

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)

Coordinating Retirement Accounts with Estate Planning (CC 07-03)

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)

December 2006

Roth IRAs, Traditional IRAs: To Convert or Not to Convert? (CC 06-44)

Asset Preservation and Long Term Care (CC 06-46)

The Del Boca Vista Widow

November 2006

New §101(j) EOLI Rules: Important Planning Considerations (CC 06-41)

Charitable Giving Incentives and Reforms Under the Pension Protection Act of 2006 (CC 06-42)

Winter Is A-Comin` In—Time for the Year End Review (CC 06-43)

October 2006

ILITs and Estate Tax Uncertainty (CC 06-37)

The Pension Protection Act of 2006: Provisions Affecting Investment Advice to Defined Contribution Plan Participants and IRA Beneficiaries (CC 06-38)

GST Tax Planning: The Key Question to Ask a Middle Generation Prospect (CC 06-39)

Proposed Regulations Curb Tax Advantages of Exchange of Property for Annuity Contracts (CC 06-40)

September 2006

Business Succession Planning That Meets the Owner`s Needs (CC 06-32)

Surviving Spouse (and Other Inheritors) IRA Strategies (CC 06-33)

The Pension Protection Act of 2006: Provisions Concerning Long-Term Care Insurance (CC 06-34)

The Pension Protection Act of 2006: Provisions Concerning Cash Balance Pension Plans (CC 06-35)

August 2006

Free Life Insurance: Risks and Costs of Non-Recourse Premium Financing (CC 06-28)

The Pension Protection Act of 2006: Provisions Concerning Tax Treatment of Employer-Owned Life Insurance (CC 06-29)

The Pension Protection Act of 2006: Provisions for Charitable Contributions Directly from IRAs (CC 06-30)

Buy-Sell Agreements and Estate Tax Valuation: PLR Holds Buy-Sell Modification Not Substantial—Does Not Trigger §2703 (CC 06-31)

July 2006

Life Insurance Offers Tax Advantaged Asset Accumulation (CC 06-25)

Maryland Legislature Responds to Chawla (CC 06-26)

June 2006

Revenue Ruling 2006-26: Guidance on Q-TIPed IRAs in UPIA States and Unitrusts (CC 06-20)

Sale By Profit Sharing Plan of Second-to-Die Policy Not a Prohibited Transaction (CC 06-21)

Watson Wyatt Survey Confirms Continuing Shift From Defined Benefit Plans (CC 06-22)

401(k) Plans Are Still Coming Up Short (CC 06-23)

New College Financial Aid Planning Considerations in UTMA to Section 529 Transfers(CC 06-24)

May 2006

Buy-Sell Agreement Fixed Estate Tax Value of Closely Held Stock (CC 06-17)

How Secure Are Retirement Nest Eggs? (CC 06-19)

April 2006

New Insurance Opportunities in Corporate Planned Giving, Part II (CC 06-13)

New York Insurance Department Renews Regulation 180, Defining "Key Executive" for Life Insurance Policies (CC 06-14)

March 2006

New Insurance Opportunities in Corporate Planned Giving, Part I (CC 06-09)

DRA 2005 Medicaid Transfer Rules (CC 06–10)

Rollovers of IRAs to Qualified Plans: An Overlooked Source of Planning Possibilities (CC 06–11)

Transitional Relief for NQDC Plans Using Off-Shore Rabbi Trusts or Financial Health Triggers—Notice 2006-33 (CC 06–12)

February 2006

IRS, on Its Own Initiative, Undermines Scheme for Avoiding Gift Tax on Transfer to Trust (CC 06-06)

Reverse Mortgages: Are They for Your Clients? (CC 06-08)

January 2006

GST Tax Update (CC 06-01)

Possible Tax Trap When Trustee of ILIT Disclaims Responsibility For Selection Of Insurance Product (CC 06-02)

What Planners Need to Know to Cope with the Coming Retirement Wave (CC 06-03)

New York Insurance Department Invalidates SOLI Scheme (CC 06-04)

IRS Notice 2005-1 Provides Guidance on New §409A Rules for Taxation of Non-Qualified Deferred Compensation (CC 05-01)

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