Income Tax

Time for the Charitable Remainder Trust to Make a Comeback

With the very real possibility that capital gains will be taxed at ordinary income rates for those making $1,ooo,ooo or more, it is time to consider the charitable remainder trust again.  A charitable remainder trust (CRT) is a split-interest trust, with the grantor receiving an income interest and charity receiving the remainder.  If you have […]

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Secure Act Shrinks the Stretch

The recently enacted Secure Act, eliminates the life time stretch of retirement assets for non-spouse beneficiaries, with a few exceptions.  Instead, these assets will now be taxed within ten years.  For the charitably minded client, one idea being touted is a charitable remainder unitrust (CRT).  Based on materials I have seen, the ideal payout rate

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The Tax Cuts and Jobs Act-How Bad Law is Created

Spent several days in San Antonio at the TexFed Tax Institute.  Most of the discussion was about the Tax Cuts and Jobs Act (“TCJA”) after two years.   The main takeaway was how poorly written the law is.  If you recall the law was put together in about three weeks.  While the lowering of the corporate

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Another Conservation Easement Bits the Dust

In theory conservation easements are simple- a landowner grants a perpetual easement on a portion of his land for a charitable purpose and gets an income tax deduction for the reduction in value to the land encumbered by the easement.   Many wealthy landowners have successfully done conservation easements.  However, they have been highly abused over

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Variable Prepaid Forward Contracts-A Monster Planning Idea

Variable prepaid forward contracts (VPFC) are used to diversify a concentrated position in a publicly traded stock, and defer tax on the sale.  Here is how they work: taxpayer (i) pledges the stock to a counterparty, (ii)  receives cash equal to a percentage of the fair market value of the stock (typically 75-85% of the

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