Owners Of Family Controlled Entities Must Act Quickly In Light Of New IRS Regulations Attacking Valuation Planning

Chapter 14 of the Internal Revenue Code consists of four Code Sections (Sections 2701 – 2704) designed to close valuation loopholes. Prior to Congress’s enactment of Chapter 14 in 1990, estate planners had a host of tools available to discount the values of assets their clients transferred during life and at death. Chapter 14 closed most of those loopholes, but many opportunities for discounts remained, particularly when clients created family limited partnerships or other […]

By |September 5th, 2016|

Netherlands And Switzerland Agree On Tax Treatment Of Investment Vehicles

Two recent mutual agreements between the Netherlands and Switzerland will have significant implications for collective investment vehicles (CIVs). One of the agreements appears to place inappropriate restrictions on certain CIVs. Dutch fiscal investment institutions, Swiss contractual funds, and Swiss open-ended investment funds can take less advantage of Dutch-Swiss tax treaty benefits when it comes to the dividends and interest that they receive from the other treaty state.

The other mutual agreement confirms that Dutch closed […]

By |September 3rd, 2016|

IRS Seeks Applications For The Advisory Committee On Tax Exempt And Government Entities

On August 26, the Internal Revenue Service (IRS) issued a notice requesting applications to serve on the Advisory Committee on Tax Exempt and Government Entities. Applications are open for the following positions:

One with federal, state and local governments;
One with Indian tribal governments; and
One with employment tax knowledge and experience in one or more areas of employee plans, exempt organizations, Indian tribal governments, tax exempt bonds or federal, state and local governments.

These […]

By |September 2nd, 2016|