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Horizontal Double Dummy Transactions – A Corporate and Tax Law Perspective (16 pp) (relevancy score: 100%)

by David W. Zimmerman Amie C. Breslow Michael J. Wilder Samuel W. Wales
from Horizontal Double Dummy: Happy Marriage of Reorgs and Tax-Free Exchanges (September 3, 2014)

After Combination Acquiror Target Shareholders Shareholders Acquiror Target 7 Situations Where Horizontal Double Dummy Structure May Be Useful · Some Target shareholders want a tax-free transaction but most want cash ­ Prototypical case ­ Earlier transactions used preferred to achieve tax-free treatment · Uncertainty as to amount of boot ­ 2006 continuity of interest regulations alleviate concern · Mergers of equals · Changing jurisdiction of acquiror (inversion transactions) 8 6 Horizontal ...

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ARTICLE: On the Brink Once More (10 pp) (relevancy score: 100%)

by Ronald D. Aucutt
from The New Estate Tax Regime: Making Sense out of Chaos (December 22, 2010)

Targeted Relief for Real Estate The Baucus Bill would have provided substantial estate tax relief for real estate. Section 302(a) establishes an estate tax applicable exclusion amount, or "exemption," of $5 million and a top estate tax rate of 35 percent, effective January 1, 2010. The GST Tax The GST tax exemption and rate will remain tied to the estate tax applicable exclusion amount and top rate, just as they have been since 2004.

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AMENDMENT: Senate Amendment to House Amendment to Senate Amendment (S. Amdt. 4753 to H.R. 4853) (8 pp) (relevancy score: 100%)

by
from The New Estate Tax Regime: Making Sense out of Chaos (December 22, 2010)

--For purposes of this section, the applicable credit amount is the amount of the tentative tax which would be determined under section 2001(c) if the amount with respect to which such tentative tax is to be computed were equal to the applicable exclusion amount. --For purposes of this subsection, the applicable exclusion amount is the sum of-- "(A) the basic exclusion amount, and "(B) in the case of a surviving spouse, the deceased spousal unused exclusion amount. (3) Section 6018(a)(1) is...

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TECHNICAL EXPLANATION: The Revenue Provisions Contained in the 'Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010' Scheduled for Consideration by the U.S. Senate (180 pp) (relevancy score: 100%)

by
from The New Estate Tax Regime: Making Sense out of Chaos (December 22, 2010)

2 A. Marginal Individual Income Tax Rate Reductions (sec. 101 of the bill and sec. 1 of the Code)...................................................................................................................... 29 J. Child Tax Credit (sec. 103 of the bill and sec. 24 of the Code) ..................................... 32 K. Increase in the Earned Income Tax Credit (sec. 103 of the bill and sec. 32 of the Code) ...

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Proposed Regulations Address Impact of a Decline in Debt Issuer's Financial Status under Debt Modification Regulations—or Do They? (6 pp) (relevancy score: 100%)

by Richard M. Lipton, Esquire
from Real Estate and Partnership Workouts (December 7, 2010)

2 3 4 5 6 2 Document Outline Proposed Regulations Address Impact of a Decline in Debt Issuer's Financial Status under Debt Modification Regulations? or Do They? 1. Proposed Regulations Address Impact of a Decline in Debt Issuer's Financial Status under Debt Modification Regulations?

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'Codification' of the Economic Substance Doctrine—Much Ado about Nothing (10 pp) (relevancy score: 100%)

by Richard M. Lipton, Esquire
from Real Estate and Partnership Workouts (December 7, 2010)

8 9 10 11 12 13 14 15 16 Document Outline 'Codification' of the Economic Substance Doctrine? Much Ado about Nothing 2. 'Codification' of the Economic Substance Doctrine? Much Ado about Nothing

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Taxation Meets Bizarro World: Passthroughs and Debt Workouts (26 pp) (relevancy score: 100%)

by Richard M. Lipton, Esquire
from Real Estate and Partnership Workouts (December 7, 2010)

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IRS Issues New Rule for Grouping Activities for Passive Loss Purposes (10 pp) (relevancy score: 100%)

by Richard M. Lipton, Esquire
from Real Estate and Partnership Workouts (December 7, 2010)

44 45 46 47 48 49 2 ALI-ABA 09/07/2010 STATE MCLE CONTACTS Alabama Delaware Indiana Minnesota Ms. Angela Parks Ms. Margot Millar Ms. Julie Orzeske Ms. Liz Vanderbeek Director of Regulatory Programs Executive Director Executive Director CLE Administrator Alabama State Bar Commission on CLE of the Supreme Indiana Supreme Court Minnesota Board of CLE 415 Dexter Avenue Court of Delaware Indiana Commission for CLE Suite 950 PO Box 671 Carvel State Office Building 30 South Meridian Street 180 East ...

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Human Issues in Estate Planning for the Closely Held Business (40 pp) (relevancy score: 100%)

by Lauren J. Wolven, Esquire
from Advanced Estate Planning Techniques for Family Owned and Closely Held Businesses (December 8, 2010)

2 Advanced Estate Planning Techniques for Family Owned and Closely Held Business ALI-ABA September 13, 2010 Webcast Course Human Issues in Estate Planning for the Family Owned and Closely Held Business Lauren J. Wolven, J.D.1 Prior to October 1, 2010 Horwood Marcus & Berk Chtd. 924586/1/88888.LWOLVEN 3 Advanced Estate Planning Techniques for Family Owned and Closely Held Business ALI-ABA September 13, 2010 Human Issues in Estate Planning for the Family Owned and Closely Held Business By ...

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Mom and Pop Want to Retire on a Full Salary – How Can the Company Afford To Do It? (50 pp) (relevancy score: 100%)

by Donald O. Jansen, Esquire
from Advanced Estate Planning Techniques for Family Owned and Closely Held Businesses (December 8, 2010)

35 4. Is the Restricted Access Executive Bonus Plan a pension benefit plan rather than a welfare benefit plan under ERISA? ............................................... C. Qualified Plans Expensive For may closely-held companies, nonqualified deferred compensation plans are the only means of deferring compensation for the top executives. An "excess benefit plan" is a defined benefit plan which provides benefits to executives in excess of the IRC Section 415 or compensation limits on ...

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Tools and Techniques for Transferring the Business to the Next Generation (154 pp) (relevancy score: 100%)

by Ronald D. Aucutt
from Advanced Estate Planning Techniques for Family Owned and Closely Held Businesses (December 8, 2010)

Use of Grantor Retained Annuity Trusts (GRATs) .................................................... A sale to a grantor trust also capitalizes on the lack of symmetry between the income tax rules governing grantor trusts and the estate tax rules governing includibility in the gross estate. - 4 - 99 C. GRATs as Grantor Trusts 1. Benefits of qualifying as a grantor trust.

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The Important Role of Life Insurance in the Closely Held or Family Owned Business (26 pp) (relevancy score: 100%)

by Charles L. Ratner
from Advanced Estate Planning Techniques for Family Owned and Closely Held Businesses (December 8, 2010)

Many policies distinguish between the "current premium" and "maximum guaranteed premium," which the company will specify in the policy. F. No-Lapse Universal Life 1. The no-lapse universal life policy, also known as "guaranteed UL", allows the policy owner to lock-in a premium that is guaranteed to support the death benefit. G. Variable Universal Life 1. Like its general account sibling universal life, variable universal life (VUL) is a flexible premium policy that allows the policyholder ...

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Roth Conversion Planning: An Outline (4 pp) (relevancy score: 100%)

by Jonathan G. Blattmachr, Esquire
from Roth IRA Conversions: What the Estate Planning Attorney Needs to Know (November 30, 2010)

2 ROTH CONVERSION PLANNING: AN OUTLINE By Jonathan Blattmachr Milbank, Tweed, Hadley & McCloy LLP New York, NY 1. Purpose of presentation: Discussion of new Roth IRA conversion opportunity next year. How qualified plans and IRAs allow income tax deferred accumulationc. MRDs for other successor beneficiaries (e.g., descendants) but no inclusion in gross income 5. 2010: The Year of the Roth IRA Rollover (YRIR--pronounced "your rear") a.

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Benefiting from Roth IRA Conversions (16 pp) (relevancy score: 100%)

by Robert S. Keebler, CPA, MST
from Roth IRA Conversions: What the Estate Planning Attorney Needs to Know (November 30, 2010)

In order to accomplish a Roth IRA conversion, the professional simply transfers all or a portion of their Traditional IRA into a Roth IRA. Benefits of Converting a Traditional IRA to a Roth IRA There are numerous benefits associated with a Roth IRA conversion. Impact of the Current and Future Projected Marginal Income Tax Rates on the Effectiveness of a Roth IRA Conversion When a Roth IRA conversion is performed in a year in which the professional's current marginal income tax rate is less ...

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A Client’s Guide to Understanding Roth IRA Conversions (10 pp) (relevancy score: 100%)

by Robert S. Keebler, CPA, MST
from Roth IRA Conversions: What the Estate Planning Attorney Needs to Know (November 30, 2010)

22 A CLIENT'S GUIDE TO UNDERSTANDING ROTH IRA CONVERSIONS One of the most powerful financial and wealth transfer planning opportunities available today is the ability to convert a traditional IRA into a Roth IRA, and in doing so convert future taxable income into future tax-free income. In order to implement a Roth IRA conversion, a taxpayer transfers all or a portion of his/her traditional IRA to a Roth IRA. Types of Roth IRA Conversions In general, there are four types of Roth IRA ...

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What Every Lawyer Should Know About Roth Conversions--Beyond the Numbers (4 pp) (relevancy score: 100%)

by Robert S. Keebler, CPA, MST
from Roth IRA Conversions: What the Estate Planning Attorney Needs to Know (November 30, 2010)

Notably, a Roth conversion raises asset protection issues, beneficiary designation issues, estate tax apportionment issues, and in some instances may require drafting of charitable lead and/or charitable remainder trusts, when appropriate, to generate an income tax deduction for a particular year. Estate Planning Matters In general, the following issues must be addressed upon a Roth conversion: · Beneficiary Designation Forms The client's beneficiary designation forms should be updated to ...

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2010 Roth Conversions (PowerPoint Presentation) (50 pp) (relevancy score: 100%)

by Robert S. Keebler, CPA, MST
from Roth IRA Conversions: What the Estate Planning Attorney Needs to Know (November 30, 2010)

> > Virilly Keeb Ter rt S. ak ights Res The "Basics" General Concepts B obe © R All R 39 4 X X X XX XXX) XX XX 2004) X, X, X, X, $X X (X $X 31/ )X X X X X X X XX X X X X X ,X XXX) ,X ,X ,X ,X ,X ,X fter 12/ X X, X $X X X X X X ($ (X ns Asio onver(C 000) onds Rule an $100,h w ess t ly) avings B Ne n SE be l I - s O E ust G A on ies (M A (IR e M ion xclusi . Virilly Keeb > Ter rt S. ak ights Res The "Basics" Roth IRA Distributions ­ Ordering Rule - B obe © R All R 47 12 e tax ...

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Roth Conversion Material (10 pp) (relevancy score: 100%)

by Robert S. Keebler, CPA, MST
from Roth IRA Conversions: What the Estate Planning Attorney Needs to Know (November 30, 2010)

A ura T r h h r K S re D D re D D w ner es fo ner es fo o A, M Ow Di RB Ow Di Afte RB Deat RB Deat Afte RB irch P Be Be V , C illy er Tr ke eebl a . T lity nor , ac istribut LLP eet he Ye ec s not y to t ed) y R e, of ission, pr the pur m onl tax IRA ot ry P ubj b liabi ount raus tily.com of for per es ent (onl ly tax ed K er es er ther es D s the to pos ion s am bak nei the tu ar ved rul pay tax ritten pur of ious eptions? inam lis e il -ups t s a es m rite bou Y E- w a er five IRA: 59½? ...

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Roth IRA Articles by Robert S. Keebler from Taxes—The Tax Magazine (22 pp) (relevancy score: 100%)

by Robert S. Keebler, CPA, MST
from Roth IRA Conversions: What the Estate Planning Attorney Needs to Know (November 30, 2010)

Total Roth IRA distribution $100,000 Chart 6. Chart 5. Total Roth IRA distribution $100,000 Total Roth IRA distribution $100,000 Less: Roth IRA contributions (30,000) Less: Roth IRA contributions (30,000) Less: Roth IRA conversion (55,000) Less: Roth IRA conversion (55,000) Taxable Roth IRA distribution $15,000 Taxable Roth IRA distribution $15,000 Total Roth IRA distribution $100,000 Total Roth IRA distribution $100,000 Less: Roth IRA contributions (30,000) Less: Roth IRA contributions (30,...

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Section 704(c) -- Practice and Theory -- Supplemental Material (42 pp) (relevancy score: 100%)

by Peter J. Genz, Esquire
from Creative Tax Planning for Real Estate Transactions (November 4, 2010)

When the contributing partner receives less tax depreciation than book, he has effectively borne the tax burden of a portion of the built-in tax gain in the 704(c) property. For depreciable property, such decreases occur as book and tax depreciation deductions are claimed with respect to the property, which cause the book-tax disparity to narrow to zero when the property is fully depreciated. The available tax items from the property are then allocated first to the noncontributing partners ...

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