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Tax Implications of Budget Reconciliation Bill
Part I of this article (in last month's issue) identified the proposed changes in partnership tax law as proposed by the Biden Administration and implemented by a Democratic Congress. The proposed changes are intended to simplify the tax law and permit the IRS to be able to audit and collect taxes in a more effective and efficient fashion. We showed how using benefit laws that have been on the books for over 30 years we can provide a seamless platform for owners of pass thru entities to reduce income estate and transfer taxes. This installment discusses how to use this platform to fund not only for death benefits but also for alternatives to deferred compensation for business and estate planning purposes for pass-through entities.
Life insurance on owners, key and top hat employees can be a powerful tool. It can generate tax-exempt proceeds that can use to help protect themselves against the death of key personnel while providing critical liquidity to the company if it must buy back shares from a deceased owner's estate. This can be especially important for pass thru entities, LLCs, LLPs, and S corporations, which often have a unique interest in controlling the makeup of their shareholders/owners to ensure continued qualification under Subchapter S.
However, life insurance policies, regardless of the type, present special considerations for S corporations. Those considerations and some of the related issues are outlined below.
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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.
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.
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.
Removing Restrictive Covenants In New York
In Rockwell v. Despart, the New York Supreme Court, Third Department, recently revisited a recurring question: When may a landowner seek judicial removal of a covenant restricting use of her land?