The Internal Revenue Code prescribes minimum imputed interest rates and time-value-of–money factors applicable to certain loan transactions and estate planning techniques. These rates are tied formulaically to market interest rates. The Internal Revenue Service updates these rates monthly. These are commonly applicable rates in effect for July 2014: Short Term AFR…
Related: E. John Wagner II
Clear FilterInherited IRAs Not Protected in Bankruptcy; Trusts Become More Desirable As IRA Death Beneficiaries
The Supreme Court of the United States has held that inherited IRA assets are not exempt from bankruptcy claims by an inheriting individual beneficiary’s creditors. In estate planning, the Supreme Court opinion may make it more desirable to name a trust as IRA death beneficiary, rather than naming an individual…
A Rebirth of Common Sense? After Ten Years, We Bid Adieu to Circular 230 Tax Disclaimers
If you received an email or letter from an attorney or CPA in the last decade, you probably have seen a Circular 230 disclaimer. Since 2004, the Internal Revenue Service has required that almost all written communications from tax practitioners concerning federal tax matters include this disclaimer notifying the reader that…
A Proposal to Better Protect Capital Gains for Real Estate Investors Before Development
We have discussed a structuring technique real estate investors use to protect the lower-federal-income-tax-rate-long-term-capital-gain treatment of real estate gains, before property is converted to an active development purpose that creates higher-tax-rate income. The structuring requires property transfers and the use of multiple business entities, which decreases transparency for the government…
The Internal Revenue Code prescribes minimum imputed interest rates and time-value-of–money factors applicable to certain loan transactions and estate planning techniques. These rates are tied formulaically to market interest rates. The Internal Revenue Service updates these rates monthly. These are commonly applicable rates in effect for June 2014: Short Term AFR…