Law.com Subscribers SAVE 30%
Call 855-808-4530 or email [email protected] to receive your discount on a new subscription.
Proposed Partnership Regulations Create Estate and Charitable Tax Planning Opportunity
The New Year and the New Administration has areas of taxation estate planning and philanthropy on the front burner. No one is sure what will be happening with the minority discounts regulations of §2504 in turmoil and proposed guidance of the modification of charities partnership interest and unrelated business taxable income (UBTI). By integrating a number of tried and tested tools, we may create a platform for substantial savings.
The idea is the Charitable Family Limited Partnership (CFLP), which is a charitable giving vehicle that provides a substantial gift to charity, produces income tax savings for the donor, transfers significant wealth to the donor's descendants and allows a means for the donor's family to retain control over the transferred assets.
The basic structure of the CFLP is that senior members, usually parents, contribute appreciated assets to a limited partnership in exchange for general and limited partnership interests. The general partners, also usually the parents, manage the affairs of the partnership and typically receive a reasonable management fee for their services. (If this fee is unreasonable, the base of this planning option perishes.) The limited partners do not participate in the CFLP's management. As general partners, the parents retain control over the property transferred to the partnership. In addition, they control the entity or person selected as investment adviser, so they determine the partnership's investments and when and if any distributions will be made out of the partnership.
This premium content is locked for Entertainment Law & Finance subscribers only
ENJOY UNLIMITED ACCESS TO THE SINGLE SOURCE OF OBJECTIVE LEGAL ANALYSIS, PRACTICAL INSIGHTS, AND NEWS IN ENTERTAINMENT LAW.
- Stay current on the latest information, rulings, regulations, and trends
- Includes practical, must-have information on copyrights, royalties, AI, and more
- Tap into expert guidance from top entertainment lawyers and experts
Already a have an account? Sign In Now Log In Now
For enterprise-wide or corporate acess, please contact Customer Service at [email protected] or 877-256-2473
Major Differences In UK, U.S. Copyright Laws
This article highlights how copyright law in the United Kingdom differs from U.S. copyright law, and points out differences that may be crucial to entertainment and media businesses familiar with U.S law that are interested in operating in the United Kingdom or under UK law. The article also briefly addresses contrasts in UK and U.S. trademark law.
The Article 8 Opt In
The Article 8 opt-in election adds an additional layer of complexity to the already labyrinthine rules governing perfection of security interests under the UCC. A lender that is unaware of the nuances created by the opt in (may find its security interest vulnerable to being primed by another party that has taken steps to perfect in a superior manner under the circumstances.
Strategy vs. Tactics: Two Sides of a Difficult Coin
With each successive large-scale cyber attack, it is slowly becoming clear that ransomware attacks are targeting the critical infrastructure of the most powerful country on the planet. Understanding the strategy, and tactics of our opponents, as well as the strategy and the tactics we implement as a response are vital to victory.
Legal Possession: What Does It Mean?
Possession of real property is a matter of physical fact. Having the right or legal entitlement to possession is not "possession," possession is "the fact of having or holding property in one's power." That power means having physical dominion and control over the property.
The Stranger to the Deed Rule
In 1987, a unanimous Court of Appeals reaffirmed the vitality of the "stranger to the deed" rule, which holds that if a grantor executes a deed to a grantee purporting to create an easement in a third party, the easement is invalid. Daniello v. Wagner, decided by the Second Department on November 29th, makes it clear that not all grantors (or their lawyers) have received the Court of Appeals' message, suggesting that the rule needs re-examination.