Asset Protection Blog

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Asset Protection Blog

Tax Reform 2017

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On December 22, 2017, the President signed The Tax Cuts and Jobs Act (the “Bill”) into law. While the effective date of most of the provisions of the Bill is not until January 1, 2018, individual taxpayers are advised to immediately review their 2017 tax situation and consider the following in order to see if there are steps they may want to take in order to reduce their income tax liability for 2017.

Limitation on Deduction of State and Local Income Taxes (or Sales Tax) and Real Property Taxes that are not effectively connected to a trade or business

Beginning January 1, 2018, taxpayers may only claim an itemized deduction for the lesser of (a) the combined amount paid for (i) State and Local Income (or Sales Tax if the amount of Sales Tax paid exceeds the amount of State and Local Income Taxes Paid) and (ii) Real Property Taxes or (b) $10,000 ($5,000 if the taxpayer is married but files a separate income tax return.)

Recommendation: Taxpayers should consider paying the balance of their 2017 State and Local Income Tax liability, including estimated tax payments normally due in January, before December 31, 2017, rather than paying them in 2018 as they may be accustomed to doing. The Conference Committee Report that accompanied the Bill makes it very clear the taxpayers will not be permitted to deduct prepayments of their 2018 State and Local Income Tax liability that are paid in 2017. Taxpayers should also consider paying their Real Property Taxes that would otherwise be due in 2018 in 2017. However, caution should be taken before doing so since the IRS has taken the position that in order for Real Property Taxes to be deductible they need to have been assessed. The burden of assessing Real Property Taxes usually falls on the taxpayer’s local municipality. To counter this position, in New York, Governor Cuomo signed an Executive Order permitting local governments to immediately issue tax warrants (in New York tax warrants are the “assessment” of Real Property Taxes) permitting the collection of real property taxes before the end of 2017. The Executive Order also suspends local tax laws through the end of 2017 which otherwise would have prevented taxpayers from making partial payments of real estate taxes.

Cautionary Note: Whether pre-paying State and Local Income or Real Property Taxes will result in an actual savings will depend in large part on whether a taxpayer is subject to the Alternative Minimum Tax in 2017.

Inability to Deduct Most Miscellaneous Deductions, Increase in Standard Deduction, Elimination of Personal Exemptions

Beginning January 1, 2018, individual taxpayers will no longer be able to claim an itemized deduction for work related expenditures, tax preparation fees, investment advisory fees and most other miscellaneous deductions that they had been able to deduct if those expenses exceeded 2% of their adjusted gross income (“AGI”). In addition, beginning January 1, 2018, the deduction for personal exemptions has been eliminated. However, beginning January 1, 2018, the standard deduction has been increased from $6,500 for a single taxpayer, to $12,000, and from $13,000 for a married couple to $24,000.

Recommendation: Taxpayers should consider prepaying their miscellaneous deductions in 2017 to the extent these expenses are known.

Cautionary Note: Again the interplay of the Alternative Minimum Tax may reduce or eliminate any actual tax savings.

Recommendation: Those Taxpayer’s who feel the increased Standard Deduction will be applicable to them 2018 should give consideration to making charitable contributions in 2017 that they might ordinarily not make until 2018 in order to benefit from the deduction. Beginning in 2018 charitable deductions will be deductible to the extent of 60% of a taxpayer’s AGI. Currently the limitation is 50% of AGI.

Limitations on Deductibility of Mortgage Interest

Beginning January 1, 2018, interest on a Home Equity Line of Credit (“HELOC”) will no longer be deductible. Interest on residential mortgages will be deductible only to the extent of the interest paid on the first $750,000 of indebtedness. Existing mortgages, those entered into prior to December 16, 2017, or those entered into after December 15, 2017 in connection with the purchase of a home pursuant to a contract that was entered into prior to December 16, 2017, are grandfathered. The refinance of a grandfathered mortgage will generally remain grandfathered provided the term/amount do not exceed the grandfathered mortgage’s term/amount.

Recommendation: Those taxpayers who have a HELOC should give consideration to converting their HELOC to a permanent mortgage, perhaps in conjunction with a refinance of their existing mortgage, as soon as practical.

Other Changes Not Requiring Immediate Action:

Change in tax brackets and rates

Beginning January 1, 2018, the top marginal tax rate for tax returns filed by married couples will be 37% on taxable income in excess of $600,000 ($500,000 for single taxpayers). Previously, the top marginal rate was 39.6% on taxable income in excess of $480,050 ($426,700 for single taxpayers).

Alternative Minimum Tax (“AMT”)

The Bill increases the exemption from the current $86,200 for married taxpayers filing a joint return to $109,400, and from $55,400, for single taxpayers to $70,300. The exemption begins to phase out for married taxpayers at $1,000,000 and at $500,000 for single taxpayers. Previously, these amounts were $164,100 and $123,100, respectively. It is anticipated that these changes, coupled with the elimination of many of the deductions that often triggered the imposition of the AMT, will lessen the impact of the AMT on many Americans.

Like-Kind Exchanges

Beginning January 1, 2018, like-kind exchanges (“§1031 exchanges”) will be limited to real property exchanges.

Section 529 Plans

Beginning January 1, 2018, withdrawals of up to $10,000 per year from a Section 529 Plan can be used to pay for tuition at an elementary or secondary public, private or religious school.

Child Care Credit

Beginning January 1, 2018, the credit increases from $1,000 per qualified child to $2,000 with up to $1,400 being refundable if the amount of the credit exceeds the taxpayer’s tax liability. The phase-out, which had begun at $200,000 for a married couple, and $75,000 for a single taxpayer, has been increased to $400,000 and $110,000, respectively.

Gift, Estate and Generation Skipping Tax Exemptions

Beginning January 1, 2018, these exemptions will be $11,200,000, per U.S. domiciliary.

Recommendation. Taxpayers who may have been considering making large gifts for estate planning purposes in 2017 which may have exceeded the current exemption ($5,490,000) should consider delaying these gifts until after December 31, 2017.

Cautionary Note. As with many provisions of the Bill, these changes will “sunset” (i.e., they will end) after 2025 and will revert back to current law.

Alimony

Effective for agreements entered into after 2018 – alimony is no longer deductible by the payor nor treated as income by the recipient.

Carry Forward of Net-Operating Loss Deductions

Beginning January 1, 2018, net operating losses carried forward from a prior year cannot be used to offset more than $500,000 of non-business income on joint returns, $250,000 for other taxpayers.

20% Deduction on Certain Pass-Through Income

Taxpayer’s receiving income from a pass-through entity (i.e., a sole proprietorship, partnership, limited liability company or Sub-S corporation) will receive a deduction equal to 20% of the income they receive. This will have the effect of reducing the marginal income tax rate on this income by 20%. The determination of the amount of the actual deduction will be depend upon a several computations which take W-2 wages paid and assets into account. In addition the amount of the available deduction will be phased out if the taxpayer’s taxable income exceeds certain threshold amounts. For those taxpayers filing joint income tax returns, the phase-out begins at $315,000 and the deduction is eliminated if taxable income exceeds $415,000. For all other taxpayers the phase-out begins at $157,500 and the deduction is eliminated if taxable income exceeds $207,500.

Corporate and Non Corporate Business Changes:

  • Institution of a flat 21% corporate tax which replaces the current tiered rate structure where rates ranged from 15% to 39%
  • Elimination of the corporate Alternative Minimum Tax
  • Reduction of dividend received deductions
  • Limitation of deductibility of interest expense to 30% of AGI, as adjusted
  • Ability to expense 100% of certain newly acquired business property placed in service after September 27, 2017, subject to certain reductions and adjustments
  • Increase of Section 179 deduction to $1,000,000, subject to a phase-out threshold of $2,500,000
  • Carried interest provision requiring assets to be held for 3 years in order to receive capital gain treatment
  • Net operating losses incurred after 2017 will be allowable only to the extent of 80% of taxable income, will not be available for carryback and will no longer be carried forward indefinitely

In addition to the changes discussed in this Update, there are many other provisions of the Bill which impact those engaged in international commerce as well as provisions impacting targeted taxpayers. We are happy to meet with you to discuss those provisions as well as to discuss how the changes mentioned in this Update may affect you and your business. We look forward to your questions.

Year-End 2017 Tax Planning, Part 2: The Tax Code is Being Re-Written; Plan Now to Preserve Tax Benefits

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There are competing “tax reform” proposals in Washington, all subject to debate, lobbying, revision and legislative vote.  The final outcome is still undetermined and these proposals are not yet law.  We can assist you in anticipating the coming tax changes and planning ahead.

Many clients are asking us: if the estate tax threshold is increasing to $11 million per person, and income taxes may be reduced, why should they care about tax minimization techniques?  We offer the following answers:

  1. Just as the laws are changing now, the laws could change again (as soon as 2018, after mid-term elections, and if a new president is elected in 2020).  Proper planning now preserves current tax benefits and provides certainty in uncertain political times.
  2. Proper tax planning also provides for:
  • Family governance and centralization of family assets
  • Legacy and succession planning (including family business and personal assets)
  • Income to beneficiaries
  • Specific family concerns and special needs children
  • Charitable considerations
  • Locking in “basis” for appreciated assets (from real estate to virtual currencies) in uncertain fiscal and political times
  • Gift tax planning. Under the current House of Representatives tax reform plan, while estate and generation-skipping taxes may be repealed or curtailed, gift tax would remain.  This presents a favorable opportunity to fund trusts.
  • Asset protection and wealth preservation
  • Privacy
  • Estate tax minimization on the state level. While Congress debates repealing the estate tax or increasing its threshold to $11 million, state estate taxes are still law in many states, including New York.
  • Preserve portability of one spouse’s estate tax exemption. While Congress allowed for portability on the federal level (back in 2012), in many states (including New York) there is no portability unless through proper estate and trust documents.

Here are a few suggestions for effective end-of-year tax planning, even while the federal tax laws continue to change:

  • If we can expect reductions in income tax rates next year, consider whether to utilize tax deductions and losses in 2017 and postpone or defer gains and income until 2018.
  • Take charitable deductions now, rather than in 2018, when tax changes could make deductions less valuable.
  • Consider an enhanced role for life insurance and an Irrevocable Life Insurance Trust (ILIT). Insurance proceeds are not taxable as income to the beneficiary.  Growth within an insurance policy is not subject to capital gains tax nor other income tax.  If the estate tax will be repealed (or the estate tax threshold doubled to $11 million per person), insurance could still be completely tax-free.  Insurance could thus play an enhanced roll in family planning, legacy planning, liquidity and tax-minimization.  An ILIT would add further benefits, including asset protection, creditor protection and extended wealth management for child beneficiaries.
  • Pay mortgage interest and state and local taxes in 2017. In 2018, these payments may not be deductible.

Please contact us to discuss strategies to lower your tax liability and preserve current tax benefits.

Year-End 2017 Tax Planning, Part 1: Leveraged Gifting to Get Assets to Your Heirs Rather Than the IRS

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A method to reduce estate taxes, which had been limited by the IRS in recent years, is now safe. This method utilizes discounting of transfers of interests in closely held entities (Family Limited Partnerships, Limited Liability Companies, family corporations) to family members. Such “leveraged gifting” has been an extremely important, effective and common method used to eliminate estate taxes.

Partners in Family Limited Partnerships (FLPs) should consider gifting limited partnership interests in order to decrease the value of their estate for tax purposes. As long as they retain their General Partner (GP) interests, they will continue to control all assets within their partnership. Yes, you can escape the estate tax and still control the assets.

In summary:

  • You can lower the value of your taxable estate, and pass up to $5,490,000 ($10,980,000 for a married couple) to your heirs, tax free. In 2018, the exclusions go up: $5,600,000 for individuals and $11,200,000 for married couples.
  • If you own an FLP, you can gift Limited Partnership (LP) interests to your heirs, and take advantage of discounting, to get even more out of your estate, tax-free. As much as $22,000,000 worth of FLP assets can be conveyed to your heirs and escape the estate tax.
  • You can keep your General Partner (GP) interests and still control the FLP and its assets, even if you gift all of the Limited Partnership (LP) interests.

Also, don’t forget about the annual gift exclusion, which allows you to gift up to $14,000 ($28,000 for a married couple) by the end of 2017 to as many people as you choose. In 2018, this amount will increase to $15,000 per person, $30,000 per married couple.

We can advise you as to appropriate FLP discounts, prepare memoranda of gift for you, as well as the partnership valuation and gift valuation calculation letters (necessary for the IRS). A recent tax court case has made it imperative that the documents transferring the LP interests be worded very carefully. These documents should be prepared by qualified tax counsel. Please contact us with any questions regarding your year-end tax planning.

 

Reminder: Extended FBAR Deadline is October 15, 2017

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We would like to remind our readers of the upcoming deadline for the FBAR form for the reporting of foreign bank and other financial accounts.  This year, 2017, is the first year that the deadline for the FBAR form, the Report of Foreign Bank and Financial Accounts (FinCEN Form 114), is the same as the deadline for submission of income tax returns (IRS Form 1040), for tax year 2016.  The extended deadline is October 15, 2017.

The FBAR must be filed by taxpayers who had beneficial ownership of, or signature or other authority over, foreign financial accounts, including bank and securities accounts, if the aggregate value of such accounts exceeded $10,000 at any time during 2016.  The FBAR also applies to foreign insurance policies, annuity policies, retirement plans and other financial products.  Recent authority also extends the FBAR to on-line gambling/gaming accounts.  Many of the foreign assets subject to the FBAR are also reportable on IRS Form 8938.  However, even if you filed Form 8938, you must still file the FBAR.

The FBAR must be filed electronically on the FinCEN website.

We can assist with questions such as:  Are you subject to FBAR reporting?  Are your foreign assets reportable on the FBAR form?  What if you have not filed the FBAR forms in past years?  Please contact us to schedule a consultation.

Changes To State Estate Taxes

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While major changes are likely on the Federal level following national elections last month (see our post here on tax changes post-elections) including the repeal of the federal estate tax, many states will still retain their own estate tax. Readers should keep in mind that on the state level, the exclusions from state estate taxes can be much lower than on the federal level. In New York, the current estate tax exemption is $4,187,500.00 and rises to $5,250,000 on April 1, 2017.  New York estates valued at 105% (or greater) of the exemption lose the exemption entirely. In Connecticut, the exemption is now $2 million and the estate tax ranges from 7% to 12%, depending on the amount above the Connecticut estate tax exemption.  (Connecticut, along with Minnesota, are the only two states in America which also impose a gift tax.)

On September 30, 2016, New Jersey Governor Chris Christie and New Jersey legislators announced an agreement to repeal the New Jersey Estate Tax. The exemption from New Jersey Estate Tax will be raised from $675,000 currently to $2,000,000 for 2017, and the estate tax is to be repealed in 2018. This will likely make New Jersey an appealing jurisdiction (like Florida) for clients from an estate tax perspective.

Contact us to discuss estate tax minimization strategies.

The Coming Post-Election Tax Code Changes Mandate Timely Planning

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Donald Trump has promised to rewrite the U.S. tax code, much like Ronald Reagan did in 1986. With a Republican House and Senate, a tax code overhaul is likely.  Trump’s plan is likely to include:

  • Reduction in income tax rates for individuals and corporations. If enacted, the U.S. would shift from one of the highest corporate income tax rates in the world, to one of the lowest (from 35% to 15%).  For individuals, the highest tax bracket is now 39.6%, plus the 3.8% net investment tax, for a total of 43.4%.  Under the Trump plan, the highest rate would be 33%.
  • Elimination or significant reduction of estate and gift taxes.
  • Restructuring of tax on offshore income, including deemed repatriation and 10% tax on deferred offshore profits.
  • Elimination or partial repeal of the Affordable Care Act (Obamacare), including repeal of the 3.8% tax on net investment income.
  • Carried interest may be taxed as ordinary income.
  • Income earned through flow-through entities (LLCs and S-Corps) to be taxed at 15% rather than higher individual rates.

Apart from the Trump tax plan, Republican legislators have also offered their own plan which also calls for reduction of taxes.

The above are proposals, not yet law.  We can assist you in anticipating the coming tax changes, and planning ahead.  Some suggestions include:

  • Take charitable deductions now, rather than in 2017, when tax changes could likely make deductions less valuable. The current income tax rates are known and will probably be higher than in 2017.
  • If we can expect reductions in income tax and capital gains tax rates next year, consider whether to utilize tax deductions and losses in 2016 and postpone or defer gains and income until 2017.
  • Consider an enhanced role for life insurance and an Irrevocable Life Insurance Trust (ILIT). Insurance proceeds are not taxable as income to the beneficiary.  Growth within an insurance policy is not subject to income and capital gains tax.  If the estate tax will be repealed, insurance could be completely tax-free.  (State estate taxes may still apply.)  Insurance could thus play an enhanced roll in family planning, legacy planning, liquidity and tax-minimization.  An ILIT would add further benefits, including asset protection, creditor protection and extended wealth management for child beneficiaries.

Year-End 2016 Tax Planning, Year-End Gifting & 2017 Tax Changes

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Year-end gifting may be changing soon. Each year, we begin our end-of-year suggestions with a reminder to clients who own FLPs, LLCs and family business ventures, that they should take advantage of year-end gifting to lower estate taxes. This year the message is even more crucial, because discounted gifting of family enterprises is about to go away entirely.  The recent election results will not alter (at least for now) this change in tax law.

Take Advantage of Year-End Gifting to Lower Estate Tax – Before the Law Changes: New IRS Regulations Eliminate the Ability to Discount the Value of FLP and LLC Gifts to Family Members

In August 2016, the IRS finally issued proposed regulations that will eliminate (or severely limit) the ability to discount the value of transfers of interests in closely held entities (FLPs, LLCs, family corporations) to family members.  Such “leveraged gifting” has been an extremely important and common method used by estate planners to eliminate estate taxes.

The proposed regulations will undergo a ninety day comment period and a public hearing on December 1, 2016.  Shortly after that, the IRS will publish final regulations which will take effect within thirty days after publication[1].  These proposed regulations were expected and we have previously written about them here.

Readers are strongly urged to contact us to implement gifts of FLP and LLC interests to their heirs before the changes take effect.  Clients with FLPs should consider gifting limited partnership interests in order to decrease the value of their estate.  As long as clients retain their General Partner (GP) interests, clients will continue to control all assets within their partnership.  Yes, you can escape the estate tax and still control the assets.

In summary:

– You can lower the value of your taxable estate, and pass up to $5,450,000 ($10,900,000[2] for a married couple) to your heirs, tax free.

– If you own an FLP, you can gift Limited Partnership (LP) interests to your heirs, and take advantage of discounting, to get even more out of your estate, tax-free (up to $21,800,000 in 2016).

– You can keep your General Partner (GP) interests and still control the FLP and its assets, even if you gift all of the Limited Partnership (LP) interests.

Also, don’t forget about the annual gift exclusion, which allows you to gift up to $14,000 ($28,000 for a married couple) in 2016 to as many people as you choose.

We realize that gifting and discounting are not simple concepts, and we welcome your questions.  We can advise you as to appropriate FLP discounts, prepare memoranda of gift for you[3], as well as the partnership valuation and gift valuation calculation letters (necessary for the IRS).  Please contact us with any questions regarding your year-end tax planning.

[1]This fall, two bills were introduced in the U.S. House of Representatives and Senate to derail the proposed IRS regulations, further illustrating the uncertain nature of our tax law.

[2] Under current law, in 2017, the exclusions go up: $5,490,000 for individuals and $10,980,000 for married couples.

[3]  A recent tax court case has made it imperative that the documents transferring the LP interests be worded very carefully.  These documents be prepared by qualified tax counsel.

New IRS Regulations Eliminate the Ability to Discount the Value of FLP and LLC Gifts to Family Members

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This month, the IRS finally issued proposed regulations that will eliminate (or severely limit) the ability to discount the value of transfers of interests in closely held entities (FLPs, LLCs, family corporations) to family members.

Such “leveraged gifting” has been an extremely important and common method used by estate planners to eliminate estate taxes.

The proposed regulations will undergo a ninety day comment period and a public hearing on December 1, 2016. Shortly after that the IRS will publish final regulations which will take effect within thirty days after publication.

These proposed regulations were expected.  We have previously written about them here and here.

While we do not venture into political discussion, we point out that Hillary Clinton has stated that she will reduce the estate tax exclusion from $5,450,000 per person ($10,900,000 for a married couple) currently in effect, to $3,500,000 per person ($7,000,000 for a married couple) and reduce the gift tax exemption from $5,450,000 per person to $1,000,000 per person.  She will also increase the gift/estate tax to 45%.  (Donald Trump has proposed to eliminate the gift/estate tax entirely.)

Readers who have not yet completed their estate planning are strongly urged to contact us to implement gifts of FLP and LLC interests to their heirs before the changes take effect.

Please contact us with any questions.

How to Lower Your Estate Tax Liability on the Federal and State Levels

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In early 2013, Congress clarified the estate tax landscape and made permanent certain provisions of estate tax law, such as the exemption from estate tax for the first $5.45 million of one’s estate, indexed annually for inflation. There has been no such clarity on the state levels, which remain a patchwork of different estate tax laws.

On the federal level, in addition to the exemption of $5.45 million each year indexed for inflation, the 40% estate tax rate is, for now, standard.  In addition, portability between spouses of an unused exemption is also now allowed.  Congress can change these laws in the future, as it has in the past.  In addition, in this election year, estate tax rates and exemptions are campaign topics and are subject to revision by a new administration.  However, at least for now, the federal estate tax regime is clear and as a result, we as tax practitioners have a better ability to plan for clients when the law is clear.

However, estate taxes on the state level are much more variable.  In New Jersey, the threshold for estate tax is only $675,000, the lowest in the U.S., and at a huge variance from the $5.45 million federal exemption.  The threshold in Connecticut is $2 million, cut from $3.5 million in 2011.  The threshold in New York is currently $3.125 million, will rise to $4.18 million on April 1, 2016 and to $5.25 million in 2017.  Ultimately, the NYS exemption will be at parity with the federal exemption amount in 2019.  In a significant quirk, a New York tax law anomaly known as “the cliff” sets the estate threshold to zero (i.e., no exemption from estate tax at all) if one’s estate is valued at $3,281,250 or more.  In other words, in New York, there is no estate tax for estates lower than $3.125 million and complete estate tax on the entirety of the estate, with no threshold and no exemption, for any New York estate valued in excess of $3,281,120.

Thus, depending on the value of one’s estate, and one’s residence, one’s estate may owe considerable state estate tax even if it is exempt from federal estate tax.

Some states have no estate tax and no income tax.  For this and other reasons (sunshine?) such states, which include Florida and Nevada, attract migration from high-tax states such as New York, New Jersey and Connecticut.

There are various strategies that one may utilize to lower one’s taxable estate on both federal and state levels.  Some of the strategies proven to reduce estate taxes are:

GRAT – If you contribute assets into a Grantor Retained Annuity Trust, you could receive a regular payment akin to an annuity over many years, and then when the trust term ends, the appreciated assets pass to your heirs, are not considered part of your estate and will not be subject to estate taxes.

QPRT – If you contribute your personal residence into a Qualified Personal Residence Trust, you may still live in the residence for a term of years, and when the trust term ends, the home is removed from your estate while passing to your heirs and will not be subject to estate taxes.

FLP – After contributing your assets into a Family Limited Partnership in return for general and limited partnership interests, you may then, over time, gift your limited partnership interests to your heirs while retaining the general partnership interest (thereby continuing to control the FLP), and thus remove the value of the limited partnership interests from your estate.  FLPs also provide the additional bonus of excellent asset protection.

CRUT – By contributing appreciated assets to a Charitable Remainder Unitrust, you are entitled to a charitable deduction, regular payments from the trust back to you during the trust term, and at the end of the term the assets pass to the charity, are not subject to income tax and are removed from your estate.

ILIT – If you own or control life insurance policies, the IRS deems their death benefit to be in your estate and subject to estate tax, even though you will never receive the death benefit during your life.  If you contribute these life insurance policies to an Irrevocable Life Insurance Trust, you may remove the insurance policies from your estate.  Your family members may receive the death benefit from the trust, free of any estate tax.

Dynasty Trust – Such a trust allows the preservation of assets for one’s immediate and remote descendants, along with offering asset protection from creditors, as well as delay of the estate tax bite for many generations.  The trust can distribute income to beneficiaries, but principal is preserved, asset-protected and grows tax-free.

These strategies are not only for the mega-wealthy.  We have successfully utilized these strategies for clients of means at various levels who are concerned with leaving as much of their hard-earned assets for their heirs with as little as possible going to the IRS and state tax authorities.  These are equally attainable goals with a $5 million estate as they are at $50 million.

Moreover, these strategies are affordable, especially considering the amount of tax savings they offer.

Of course, if you want to move to Florida or Nevada, go for it.  But if you’re considering a move for estate tax reasons, first consider these various strategies to lower your estate tax liability without having to relocate.