How Private Placement Life Insurance Helps Protect and Grow Your Wealth

It seems like every day there is a new “big idea” for shielding both wealth and income from the long reach of the IRS. Surprisingly, the latest hot take on tax reduction and wealth protection centers on an investment most people consider about as trendy as an over-60 men’s bowling league: life insurance. Background: Types Read more about How Private Placement Life Insurance Helps Protect and Grow Your Wealth[…]

LB&I’s Micro-Captive Insurance Campaign: Illegitimate Insurance Carries Huge Risk of IRS Scrutiny

In recent posts, including my December 2017 article on OVDP Withdrawals and Rejections, I have described several of the issue-specific “compliance campaigns” launched by the Large Business and International (LB&I) division of the IRS in 2017. One of those campaigns focuses on abuse of the rules governing the creation of captive insurance companies. What Are Read more about LB&I’s Micro-Captive Insurance Campaign: Illegitimate Insurance Carries Huge Risk of IRS Scrutiny[…]

How Conservation and Preservation Easements Offer Huge Tax Benefits

Conservation and preservation easements offer taxpayers some of the largest charitable contribution deductions to be had under the U.S. tax code, which is extraordinary when one considers that no property actually changes hands under such an agreement. Rather, the owner of the land, building, or art collection in question maintains his or her ownership but Read more about How Conservation and Preservation Easements Offer Huge Tax Benefits[…]

The LB&I OVDP Declines and Withdrawals Campaign: An IRS Enforcement Initiative With Known Targets

In a recent article on Deducting S Corporation Losses in Excess of Basis, I explained that the Large Business and International (LB&I) division of the IRS signaled a shift in enforcement tactics with its 2017 announcement of 13 issue-specific “compliance campaigns.” Eleven additional campaigns were launched in November 2017, suggesting that the initial 13 are Read more about The LB&I OVDP Declines and Withdrawals Campaign: An IRS Enforcement Initiative With Known Targets[…]

Filing Your IRS Form 1120-F: Announcing Yourself Is Better Than Disqualifying Yourself

As I described in a previous post on Deducting S Corporation Losses in Excess of Basis, the IRS announced a shift in 2017 toward issue-specific enforcement practices for its Large Business and International (LB&I) division, built around 13 initial “compliance campaigns.” One of those campaigns centers on Form 1120-F, which many foreign business entities conducting Read more about Filing Your IRS Form 1120-F: Announcing Yourself Is Better Than Disqualifying Yourself[…]

Deducting S Corporation Losses in Excess of Basis

In February of 2017, the IRS announced a major shift in enforcement methods for its Large Business and International (LB&I) division, with the revamped approach centering on issue-specific “campaigns.” The initial 13 campaigns are already underway. In past years, the enforcement activities of the LB&I have predominantly consisted of audits of the largest corporations, with Read more about Deducting S Corporation Losses in Excess of Basis[…]

Trust Matters: Employment Taxes, Payroll Taxes Are Serious Business

Over two-thirds of the tax revenues collected by the IRS come from deductions from employee paychecks—withheld income tax and FICA taxes. (FICA stands for Federal Insurance Contributions Act, the principal funding source for Social Security and Medicare). These taxes are sometimes referred to collectively as Employment Taxes, or Payroll Taxes. Given their vital importance to Read more about Trust Matters: Employment Taxes, Payroll Taxes Are Serious Business[…]

Sea Shells: Pros and Cons of Starting an LLC for Yacht, Jet, Golf Cart, or Other Vehicle Ownership

If you purchase a yacht or jet that will be used for the conduct of your business ventures, the acquisition should of course be structured so that the ownership of the vehicle clearly falls to your company, not to you personally. Most often, the appropriate business structure is a Limited Liability Company (LLC), which offers Read more about Sea Shells: Pros and Cons of Starting an LLC for Yacht, Jet, Golf Cart, or Other Vehicle Ownership[…]