September 13, 2021— Yesterday, Finseca got hold of a list of tax increases planned to pay for the $3.5 trillion dollar ‘soft’ infrastructure package. This is an early document, and we expect changes before the bill reaches President Biden’s desk – candidly, it could change as soon as tomorrow.
“Intergenerational Split Dollar Planning Can Still Work. While Estate of Morrissette may encourage practitioners to transition away from recommending economic benefit split dollar arrangements, it is important to consider the impact that certain bad facts specifically noted by the Court in this case had on the decision. The results in this case may not significantly affect IGSD planning under the economic benefit regime, provided that the plan is established for the right non-tax reasons, the facts substantiate the treatment of the IGSD plan as a bona fide sale, and conservative discounts are taken when valuing repayment rights.”
An interesting article by Laura Saunders for the Wall Street Journal on July 2, 2021.
“Large Roth IRAs owned by the superrich are in the tax spotlight now, and all savers should consider the implications for their own retirement accounts….The story [ProPublica] claimed some wealthy Americans have multimillion- or even billion-dollar, tax-advantaged retirement-savings accounts. The largest one cited was a Roth IRA with $5 billion in assets (as of 2019) belonging to PayPal founder and investor Peter Thiel.”
“Now that we have the Green Book, which covers all of the same ground as the STEP Act, it seems that we no longer need to be concerned with retroactive provisions and can advise clients to take certain proactive steps….Green Book = Green Light.”
“Well-meaning advisors and their studious clients are not always running the numbers to help ensure that the strategies and techniques they are using will provide the best-expected results….We have found from years of experience that there is no substitute for taking out a calculator or spreadsheet and reviewing the most probable scenarios (as well as possible or unexpected situations) to determine the expected and non-expected outcome of any given technique in order to produce the most accurate map possible of the estate planning territory.”
“As part of their comprehensive legacy plan, clients who are charitably inclined, hold significant highly appreciated assets, and wish to create a lifestyle “annuity” should consider a CRT, especially if they can benefit from an income tax charitable deduction. Selling an appreciated asset inside a CRT may provide an economically superior result compared to selling the same asset in a client’s own hands, especially when done in conjunction with purchasing additional life insurance through an irrevocable life insurance trust (“ILIT”).”
“Individuals and businesses in high tax jurisdictions have been expressing unprecedented interest in relocating to states with more manageable tax regimes. This is especially the case with business owners looking to sell their businesses. But whether this trend rises to the level of an “exodus”—as many characterize it—is up for debate. The impetus for moving typically runs deeper than just taxes, though taxes often are the proverbial final straw. This article analyzes tax issues individuals and businesses should consider when evaluating whether to relocate from California or New York.”
All of us are use to face-to-face meetings. We have always believed that they are essential. Now, a year into the pandemic, I wonder what we think now? An interesting Op-Ed in today’s NY Times.
“How many of those trips would have been unnecessary if I’d only Zoomed? My estimate runs somewhere between most and all. Aviation is a modern miracle; it is also expensive, annoying and environmentally costly. Now that videoconferencing has been shown to be an acceptable way to get work done, there’s no reason to quit it when the virus is gone. For years, it has been a truism that face-to-face meetings are far better than videoconferencing, for obvious reasons. They foster deeper relationships and perhaps better group decision-making. “I grew up in a sales culture that said, ‘You want to close a deal, you go get in front of the client,’” said Darren Marble, an entrepreneur based in Los Angeles who used to travel to New York every other week. When the pandemic hit, he didn’t know how he’d do business. “Working at home was antagonistic to everything I’d learned over my career,” he said. But in the Zoom era, everything worked out. In fact, Marble told me, 2020 was a “breakout year”; his firm, Crush Capital, recently raised more than $3 million from over 30 investors, all through Zoom. “Rapport is overrated,” Marble said.”
“When you’re planning to divide your estate unequally, explain the reasons to your heirs, and remember: They might be hurt anyway….For most older parents, it is simpler to leave each adult child the same inheritance. But is equal always equitable? For many, the answer is no. And as the pandemic drives people to draft or update their estate plans, more are confronting that question….While leaving equal inheritances is the norm, many parents appear open to bequeathing their adult children different amounts. Two-thirds of Americans 55 and older said a child who provided them care should get a bigger inheritance than children who did not….The survey also found that one in four parents said an adult son or daughter who has children should receive more than a child who does not.”