However, the Service has met with limited success in combatting these discounts. The success they have had is often due to the taxpayer’s poor planning or the taxpayer’s failure to observe the formalities of the transfer and of the post-transfer ownership requirements. When done appropriately, the discounts are allowed although there is often a compromise if a taxpayer is audited. E.g., Taxpayer claims a 44% discount, the IRS initially offers a 15% discount, the parties settle for a discount of 35%. … [Read more...] about Are Asset Discounts on Family Transfers a Thing of the Past?
When transfer market close
Lock-In Low Rates for 5-10 Years. Clients may wish to lock in these historic low interest rates for a term longer than two years (such as five or 10 years), particularly for an asset with longer-term appreciation potential or a portfolio of marketable securities. Many wealth management advisers believe that the historical performance of the equity markets should far exceed 1.4% on an annual basis in the mid to long term. Although the longer trust term may increase the possibility of losing the tax benefits due to the grantor’s death during the term, it may be a reasonable risk for younger and middle-aged clients. … [Read more...] about The Perfect “GRAT” Storm: Record-Breaking Low Interest Rates and Depressed Financial Markets
Neymar is unique in world football. Whilst he has not yet won FIFA’s Ballon d’Or (renamed Best Men’s Player), to many he is seen as the best player in the world. At 25 years old he is at the peak of his career and an exceptional talent. Off the pitch with followers numbering 60 million on Facebook; 33 million on Twitter; and 82 million on Instagram, Neymar represents a new era of the Social Media Galaticos. Players have long been acquired for both their on and off pitch returns but with the increasing digitisation of sport, an element to take account of in any transfer fee are direct off pitch revenues that a player can generate. Neymar has demigod like status in his home country of Brazil and carries a global recognition which the types of sponsors that PSG want to attract look for. In terms of putting PSG on the world stage, walking into a club like Barcelona and taking one of their star players from under them was a huge coup. … [Read more...] about UEFA’s Financial Fair Play Regulations: Neymar, Mbappe and PSG’s transfer policy – “Financial Doping” or Market Forces?
On January 9, 2009, federal legislation (HR 436) was proposed that, if enacted, would eliminate valuation discounts relating to transfers of closely held business interests to the extent of the entity's non-business assets. This legislation especially affects estate planning with regard to family limited partnerships holding cash, bonds, marketable securities and/or real estate (with an exception for real estate activities where more than 750 hours of services are rendered during a taxable year). … [Read more...] about Quick Action: Proposed Legislation May Adversely Affect Transfer Taxation of Closely Held Business Interests
“…it’s obvious that there are more foreigners in our league than others. In Serie A 53 per cent of the players are foreign while it’s 15 or 20 per cent elsewhere. I agree with having foreign players in the league but they should at least be strong. There are too many average players who keep young Italians out of their sides. We need to know how to give youth a chance, only like that will the national team continue to be competitive.” … [Read more...] about The Chinese Player Transfer ‘Tax’: An Analysis