Attorneys for Family-Held Enterprises (afhe)的动态

16 years ago, in the tax LL.M. program, I remember dealing with Code Section 304 and being extremely confused. But, someone in our class found Andrew Mitchel's tax charts (https://lnkd.in/gstNbfpq) - one of which illustrates this Code Section - and I remember being blown away by how helpful they were. Andrew's resources planted some of the seeds of the work I do now. The charts, however, did not prevent me from having writer's block when it comes to Code Section 304 - in particular as the next chronological topic in my series on C and S corporations for estate planners. Yet, I finally took a chance on publicly re-learning this topic 15 years after the fact and boiling it down. Unfortunately, a written description cannot do it justice. So, while this article has my analysis of Code Section 304, I plan to follow-up with visual illustrations of the transactions, attributions, and other issues inherent in the application of this Code Section. But, my key takeaway for you as the reader is not mastery - especially of this topic. It is, instead, to become a better issue-spotter when dealing with estates and trusts holding corporate stock so as to better determine applicable tax treatment. #estateplanning #trustsandestates #tax #financialplanning #cfp #wealthplanning #wealthmanagement #taxstrategies #taxcompliance

C-corporation shareholders within the realm of businesses possessing assets valued at less than $50 million are urged to strategically contemplate the optimization of the prevailing $13.61 million estate tax exemption via a method known as "Stacking," especially in light of the imminent expiration of this exemption by the conclusion of 2025. In our latest DE Insight, Benjamin Miller articulates a highly effective approach to this end, one that promises to be instrumental in fortifying both your personal financial strategies and the legacies you intend to impart to your successors. #qsbs #estateplanning #estateplanningattorney #privatewealthplanning #DEinsights

Where C or S corporation shares are transferred, especially during life, there can be some messy issues. There may be income-shifting limitations for service income from S corporations. Phantom income and the demands of passive shareholders can create a tension between retention of cash for business purposes, and the need for dividend distributions. And, especially for S corporations, grantor trusts may be a necessity - introducing several headaches such as grantor trust status, the scope of a substitution power when it comes to voting stock, tensions between tax distributions/withholding at the entity level and the grantor's income tax liability, and added wrinkles for unintended dividends (through failed redemptions or otherwise). In this article, I discuss these issues and more. #estateplanning #trustsandestates #tax #financialplanning #cfp #wealthplanning #wealthmanagement #taxstrategies #taxcompliance

?? Watch out social media tax saving gurus ?? There are an increasing number of young and trendy accounting gurus on social media offering simplistic tax advice to entrepreneurs about avoiding high taxation rates. The recent case of Rupert Grint's, and others like it, could lead to a backlash against social media gurus who offer this oversimplified or misleading tax advice: ?? High-profile cases draw public attention to the risks of following unverified advice. People may become more sceptical of quick-fix solutions and seek more reliable sources. ?? When individuals face significant financial penalties due to poor advice, it can lead to frustration and a loss of trust in those who provided the advice. This can result in negative reviews and a decline in the popularity of these "gurus." ?? Authorities may increase scrutiny on misleading financial advice, leading to stricter regulations and enforcement actions against those who provide it. ?? Social media platforms often have active communities that share experiences. Negative experiences with tax advice can quickly spread, leading to a collective backlash. It is crucial for individuals to verify the credentials of those offering advice and to seek professional guidance for complex financial matters. https://lnkd.in/eQXNdB2e #TaxAdvice #FinancialPlanning #HMRC #RupertGrint #TaxLaw #AccountingTips #ProfessionalAdvice #Taxation #BusinessFinance

Discover the fundamentals of establishing a C Corporation, covering the key benefits and drawbacks, the process of setting up a C Corp, identifying its key players, considerations for federal income tax, among other important aspects. Dive into expert analysis here: https://gag.gl/44g9aK? #ccorp #businessformation #business #compliance

Everyone likes some goodwill this time of year (and most times), especially when it carries tax advantages. ?? ?? ?? ?? ?? ?? ?? ?? Now that I've warmed up the room with that great joke, here's a guide with expert insights from Corey Kupfer of Kupfer., PLLC and Thomas Phelan of Troutman Pepper on personal goodwill transactions in M&A deals for advisory practices. #taxstrategy #financialadvisors #mergersandacquisitions #tax #financialplanning https://lnkd.in/gThubxPK

For high-net-worth individuals and business owners, this dramatic change could significantly impact how much of their wealth is protected from taxes. Read more ?? https://lttr.ai/AXGA2 #TaxLaw #BusinessOwnership #FamilyBusiness #2024Election #EstatePlanning #BusinessOwner #ProfessionalServiceFirms #SuccessionPlanning Thank you Doug McCullough with Crady Jewett McCulley & Houren LLP and Loyd "Champ" Rawls with Rawls Succession Planners

C Corp vs. S Corp: A Simple Guide A C Corp is a traditional corporate structure. It's taxed separately from its owners, meaning the corporation pays taxes on its profits, and then shareholders pay taxes on any dividends they receive. This is known as double taxation. C Corps are great for businesses with many shareholders or those seeking to raise large amounts of capital. An S Corp, on the other hand, is a special type of corporation. It passes its profits and losses directly to its shareholders, who then report them on their personal tax returns. This can lead to significant tax savings. However, S Corps have stricter ownership rules, limiting the number of shareholders and requiring them to be individuals or certain trusts. When to Choose Which? Choose a C Corp if: ??You have many shareholders or plan to raise a lot of money. ??You need to offer different classes of stock. ??You want to protect your personal assets from business liabilities. Choose an S Corp if: ??You have a small number of shareholders. ??You want to avoid double taxation. ??You're a single-member LLC looking to reduce self-employment taxes. Feel free to reach out in case you need some specific guidance.

C Corp vs. S Corp: A Simple Guide A C Corp is a traditional corporate structure. It's taxed separately from its owners, meaning the corporation pays taxes on its profits, and then shareholders pay taxes on any dividends they receive. This is known as double taxation. C Corps are great for businesses with many shareholders or those seeking to raise large amounts of capital. An S Corp, on the other hand, is a special type of corporation. It passes its profits and losses directly to its shareholders, who then report them on their personal tax returns. This can lead to significant tax savings. However, S Corps have stricter ownership rules, limiting the number of shareholders and requiring them to be individuals or certain trusts. When to Choose Which? Choose a C Corp if: ??You have many shareholders or plan to raise a lot of money. ??You need to offer different classes of stock. ??You want to protect your personal assets from business liabilities. Choose an S Corp if: ??You have a small number of shareholders. ??You want to avoid double taxation. ??You're a single-member LLC looking to reduce self-employment taxes. Feel free to reach out in case you need some specific guidance.

Marginal tax bracket and holding period affect capital gains taxes. Learn more.