Tag Archives: asset protection

Recent IRS Developments

A.      Recent IRS Developments Field audits of taxpayers with incomes exceeding $200,000 rose 34 percent in fiscal 2011 to 78,392. IRS Deputy Commissioner Steve Miller stated that “[w]e are looking more at taxpayers at these income levels because we … Continue reading

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Tax News & Comment — April 2011

View Issue: Tax News & Comment — April 2011 pril 14, 2011 I. ESTATE TAX RETURNS Calculation and remittance of federal and NYS estate tax is of primary concern in administering an estate. An estate tax return must be filed … Continue reading

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Tax News & Comment — June, 2010

To view full issue: Tax News & Comment — June, 2010 To View Full Issue:  Tax News & Comment — June, 2010 The June, 2010 issue of Tax News & Comment, in “From Washington,”  discusses the new $56 billion tax … Continue reading

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Estate Planning in 2010: Treatise

Estate Planning in 2010: Treatise PDF:  Estate Planning Outline © 2010 David L. Silverman, J.D., LL.M. (Taxation) Law Offices of David L. Silverman 2001 Marcus Avenue, Suite 265A South Lake Success, NY 11042 (516) 466-5900 July 26, 2010 Estate Planning … Continue reading

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Asset Sales to Grantor Trusts: Antidote to New Estate Tax?

PDF:   Sales of Assets to Defective Grantor Trusts I.     Introduction   Asset sales to grantor trusts exploit income tax provisions enacted to prevent income shifting by capitalizing on different definitions of “transfer” for transfer and income tax purposes. The objective … Continue reading

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Marital Deduction Planning

PDF: Marital Deduction Planning.wpd I.    Review of Current Wills   The estate tax will resume no later than January 1, 2011. At that time, the exemption amount may be $1 million (if Congress fails to do anything), or it could … Continue reading

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House Passes $56 Billion “Tax Extenders” Bill

The House, on May 29, by a vote of 215-204, approved a $56 billion tax bill, the “American Jobs and Closing Tax Loopholes Act”. The Senate has already approved a similar measure. President Obama is expected to sign the bill. … Continue reading

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New Carryover Basis Rules

Prior to 2010, property acquired from a decedent generally received a stepped-up basis under IRC § 1014. The purpose of the statute is to avoid the double taxation that would result if the asset were first subject to estate tax … Continue reading

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Modifying or “Decanting” Irrevocable Trusts

Despite the best efforts of drafters to contemplate unforeseen circumstances, situations arise where dispositive trust provisions may not reflect the present circumstances of beneficiaries. If the trust is revocable, and the grantor is alive, the grantor may revoke or amend the trust. However, trusts are often made irrevocable for tax or asset protection purposes. In those cases, revoking the trust, while not impossible, may be extremely difficult, especially if minor beneficiaries are involved. Continue reading

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DELAWARE ASSET PROTECTION TRUSTS ECLIPSE OFFSHORE ENTITIES

EPTL § 7-1.3 provides in stark language that “[a] disposition in trust for the use of the creator is void as against the existing or subsequent creditors of the creator.” This prohibition against self settled spendthrift trusts has led some New York residents to create asset protection trusts in exotic places such as the Cayman or Cook Islands, or in less exotic ones, such as Bermuda or Switzerland. Continue reading

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Asset Protection Seminar: July 27, 2010 in Lake Success, NY

Download Seminar Invitation:  Asset Protection Seminar Invitation I would like to register for the July 27, 2010 Asset Protection Seminar:

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Asset Protection for Professionals

Asset protection is best implemented before a creditor — judgment or otherwise — appears, since a transfer made with the intent to hinder, delay or defraud a creditor may be deemed a “fraudulent conveyance” subject to rescission. Asset protection may consist of simply gifting or consuming the asset. Continue reading

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ASSET PROTECTION: ETHICAL CONSIDERATIONS

New York County Surrogates Court, in In re Joseph Heller Inter Vivos Trust, 613 N.Y.S.2d 809 (1994), approving a trustee’s application to sever an inter vivos trust to “insulate[] the trust’s substantial cash and securities from potential creditor’s claims that could arise from the trust’s real property, observed that “New York law recognizes the right of individuals to arrange their affairs so as to limited their liability to creditors, including the holding of assets in corporate form . . . making irrevocable transfers of their assets, outright or in trust, as long as such transfers are not in fraud of existing creditors.” Continue reading

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Requirement of Filing Federal Gift Tax Return

The requirement of filing a federal gift tax return arises when one has made a completed taxable gift. Incomplete gifts do not impose any gift tax filing requirement. Thus, the donor’s gift of a diamond ring would exemplify a completed gift. However, if the donor reserved the power to revest beneficial title in the ring to himself at a later date, the gift would be incomplete.
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Delaware Dynasty Trusts

Traditionally, trusts were viewed primarily as a means to protect immature or dysfunctional beneficiaries from themselves. Traditional trusts typically terminated when a minor child attained a certain age. Dynasty Trusts, on the other hand, seek to maximize all of the benefits of the trust arrangement, which include asset protection and tax savings, as well as the traditional objective of protecting immature or spendthrift persons. In fact, the Dynasty Trust can serve as the centerpiece of an estate plan. Continue reading

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