Proposed regulations were issued in November under Code Section 2010 addressing the possibility of “clawback” when the temporary high exemption amount reverts to pre TCJA levels (adjusted for inflation). The good news is that the proposed regulations state that clawback
McGuire, Craddock & Strother
McGuire, Craddock & Strother is a law firm that publishes content focused on estate planning, tax law, and related financial strategies. Their blog posts discuss topics such as retirement asset taxation, grantor retained annuity trusts (GRATs), valuation methods in tax litigation, trust planning techniques like the Beneficiary Deemed Owned Trust (BDOT), and critiques of tax legislation such as the Tax Cuts and Jobs Act. The firm provides analysis and practical insights aimed at clients and professionals interested in tax-efficient wealth transfer, trust structuring, and navigating complex tax regulations.
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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. …
Update on Qualified Opportunity Funds
Proposed regulations on Qualified Opportunity Funds (QOF) were released at the end of October. The regulations are complex, and a complete analysis is beyond the scope of a blog post. However, there are some interesting provisions to note:
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Fun with Sales of S Corporation Stock
S corporations are pass through entities, but lack the flexibility of partnerships. When more than 20% of the stock of an S corporation is sold, the issue arises as to how to account for income to the shareholders during the…
Rethinking that LLC
The common wisdom is to select an LLC for a new business. That wisdom needs to be scrutinized. Sure forming an LLC is easy. Generally, the filing fees are less than a corporation, and the documentation is less complicated.
While…
Qualified Opportunity Zones
Practice the Hard Things
Many times we shy away from doing the hard things that we need to do to improve. For example, in golf everyone is trying to get more distance. Many try to get there by getting a super light driver or…
Newly Issued Proposed Regulations under Code Section 199A
On August 8, 2018 the Treasury issued proposed regulations under Code Section 199A, a provision that was part of the 2017 tax act that provides a 20% deduction on “qualified business income.” Code Section 199A is a very complex provision,…
Know Where You Are Going
Golf break: A more sophisticated way to work the ball. I give credit to instructor John Erickson for teaching me this.
The Role of the Probate Lawyer
The legal role of the probate lawyer is to admit the decedent’s will to probate, advise the newly appointed executor on their responsibilities and duties, help the executor inventory all of the assets of the decedent’s estate, settle debts and…
