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More Scrutiny of Donor Advised Funds

More Scrutiny of Donor Advised Funds

December 8, 2017

Authored by: Keith Kehrer

Notice 2017-73, released on December 4, 2017, describes potential approaches that may be taken to address issues raised regarding the use of donor advised funds (“DAF”). The Treasury and IRS are considering developing proposed regulations under § 4967 of the Internal Revenue Code (Code) that would, if finalized, provide that: (1) certain distributions from a DAF that pay for the purchase of tickets that enable a donor, donor advisor, or related person to attend or participate in a charity-sponsored event result in a more than incidental benefit to such person under § 4967; and (2) certain distributions from a DAF that the distributee charity treats as fulfilling a pledge made by a donor, donor advisor, or related person, do not result in a more than incidental benefit under § 4967 if certain requirements are met. In addition, the Treasury Department and the IRS are considering developing proposed regulations that would

Summary of Income, Business, and International Provisions in New Tax Bill

November 3, 2017

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Our colleagues in our Tax Advice and Controversy group have also summarized the proposed changes to individual, business, and international taxes in the new bill released on November 2 by the House Ways and Means Committee.

SUMMARY OF NEW TAX BILL PROPOSAL

November 3, 2017

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SUMMARY OF NEW TAX BILL PROPOSAL

November 3, 2017

Authored by: Charles Lin

House Republicans released their new tax bill on November 2, 2017.  As expected for such a significant proposal, the final bill, if passed, will likely look different.  Nonetheless, the bill, in its current form, provides the base starting point from which the House GOP intends to negotiate, both within their party and without.

The changes in the tax bill related to transfer taxes are as follows:

  • The transfer tax exemption for gift, estate, and GST purposes is doubled in 2018, from $5,000,000 per person to $10,000,000, as previously indexed for inflation – $11,200,000 per person – and indexed from there.
  • The estate and generation-skipping transfer tax will be fully repealed on January 1, 2024.
  • “Step-up” basis on death for income tax purposes of inherited property (presumably other than retirement plan benefits and other items of “income in respect of a decedent”) would remain in effect, even after 2023,

Arboneaux Ranked in ‘Private Client Global Elite 2017’

October 26, 2017

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London Partner, Dyke Arboneaux, was profiled in The Private Client Global Elite 2017 – a special publication of Legal Week compiled every five years in recognition of the top 200 private client and trust practitioners across Europe, the U.S. and Asia.Arboneaux advises on the international aspects of U.S. tax matters and estate planning, with a particular specialty in planning for clients who are exposed to multiple tax systems. She leads a team of FATCA specialists within Bryan Cave who have extensive experience advising small to medium-sized trust companies, private investment funds, and complex private trust and company structures on FATCA compliance.

Those included in the publication were celebrated at a gala dinner on Oct. 4. This is the second time Arboneaux has been featured in The Private Client Global Elite; she

Treasury to Withdraw Proposed IRC §2704 Regulations

Treasury to Withdraw Proposed IRC §2704 Regulations

October 26, 2017

Authored by: Andrew Bleyer and Larry Brody

The Department of the Treasury has withdrawn the controversial proposed regulations for Section 2704 of the Code.  Section 2704 limits valuation discounts in family-controlled entities for certain lapsing rights and restrictions.  The proposed Regulations would have expanded the scope of Section 2704 by adding a new classification of disregarded restrictions and by narrowing several longstanding exceptions.  Comments submitted after the regulations were proposed complained that the requirements were unclear and that the impact on state law was difficult to predict.  On October 2, 2017, the Department of the Treasury submitted a report recommending that the proposed 2704 Regulations be rescinded and today the proposed Regulations were officially withdrawn by notice published in the Federal Register (82 FR 48779).

Chambers High Net Worth Guide 2017

September 20, 2017

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Chambers High Net Worth Guide 2017

September 20, 2017

Authored by: Tiffany McKenzie

Bryan Cave is recognized in Chambers High Net Worth (HNW) 2017 guide.  Now in its second edition, the HNW guide covers the private wealth market in key jurisdictions around the world and features the world’s leading high net worth advisers.

Firm Rankings Georgia – Private Wealth Law (Band 2) Missouri – Private Wealth Law (Band 1)

Individual Rankings in Private Wealth Law USA Lawrence Brody (Band 2) Kathleen R. Sherby (Band 3)

Georgia Kimberly E. Civins (Band 3) William Linkous Jr. (Senior Statesmen)

London (Firms) Dyke Arboneaux (Foreign Expert for USA)

Missouri Lawrence Brody (Band 1) Stephen B. Daiker (Band 2) Kathleen R. Sherby (Band 1)

Click here to view the High Net Worth guide.

For more information about Chambers and Partners,

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