This memorandum explores the complex interplay between the partnership income tax rules of IRC Section 754 governing inside basis adjustments to partnership assets upon the sale of a partnership interest to an irrevocable non-grantor trust in exchange for an installment promissory note governed by...
The global stock market rally continued in 2024 against a backdrop of continued global economic expansion and moderating inflation. Most asset categories exhibited positive calendar year returns, though the rise in Treasury bond yields and strong US dollar created a headwind in the fourth...
Tax Legislation With recent Republican victories in the U.S. presidential, Senate, and House races, significant tax policy changes are expected in 2025, particularly regarding provisions of the Tax Cuts and Jobs Act of 2017 (TCJA), many of which are scheduled to expire on December 31, 2025. While...
This article is Part 3 of a 4-part series exploring various tax issues related to disregarded and regarded intra-family installment sale transactions for estate and income tax planning. Part 1 focused on loans and debt transactions between trusts and their beneficiaries. Part 2 reviewed the income...
We are reaching out with our latest market review and investment outlook commentary. The linked file includes a review of recent financial market results, our assessment of the macro backdrop, and an update on portfolio strategy. The piece also includes a discussion of the current level of...
This article is Part 2 of a 4-part series exploring various tax issues related to disregarded and regarded intra-family installment sale transactions for estate and income tax planning. Part 1 focused on loans and debt transactions between trusts and their beneficiaries. Part 2 reviews the income...
For years, wealthy families and their advisors have utilized intra-family loans and installment sale transactions as part of an overall estate planning strategy to shift wealth tax efficiently between generations. In fact, installment sales of appreciating assets between grantors and grantor...
After the broad-based downturn in 2022, most asset categories rebounded in 2023 against a backdrop of continued economic expansion and moderating inflation. Global stock and bond markets experienced a strong year-end rally as the US Fed signaled a potential shift to monetary easing. Yet...
Tax Legislation A politically divided Congress struggled to pass any form of meaningful legislation in 2023. There had been some discussion around extending or modifying certain expiring tax provisions of the Tax Cuts and Jobs Act (TCJA). Expiring TCJA provisions were not the only tax items...
The combination of continued global economic expansion with moderating inflation provided a favorable backdrop for financial markets in the first half of 2023. Corporate earnings results were generally better than expected, which improved investor sentiment toward equities. The US market rally was...
Despite some weakness thus far in August, the combination of continued global economic expansion with moderating inflation has provided a favorable backdrop for riskier assets thus far in 2023. So far, the economy and corporate profits have proved more resilient than the consensus expected. Despite...
Ultra-affluent families with excess capital often have dual goals of charitable giving and preserving wealth for future generations. The Charitable Lead Trust (“CLT”) is an ideal vehicle for accomplishing these competing objectives. Please click here to read more.
