Arizona  CPA - Certified Public Accountant

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Anti-Tax-Shelter Efforts
  • Sharply limiting benefits from abusive leasing transactions with tax-indifferent parties ("SILO" transactions use to "acquire" significant tax benefits from a tax-indifferent party, such as a municipal transit authority or foreign government, in exchange for a modest fee).
  • Denying foreign tax credits for foreign withholding taxes imposed on income if the underlying property generating the income was not held for a specified minimum period of time, and providing Treasury with regulatory authority to prevent transactions that inappropriately separate foreign taxes from the related foreign income to take advantage of the foreign tax credit rules where there is no real risk of double taxation.
  • Treating an income-separation transaction as a secured borrowing, not a separation of ownership.
  • Preventing taxpayers from misusing the rules for tax-exempt casualty insurance companies to improperly accumulate investment income tax-free.
  • Tightening the deduction limitation for related party interest to curb the opportunities available under current law to inappropriately reduce taxes on U.S. operations through the use of foreign related party debt.
  • Imposing additional appraisal requirements on charitable contributions to curb inflated deductions, and, in the case of patents and certain other intellectual property, limiting the amount that can be deducted.
  • Preventing the use of Section 529 college savings plans to avoid transfer taxes.
  • Imposing a new civil penalty for the failure to disclose foreign financial accounts.
  • Eliminating the statutory practitioner-client privilege with respect to tax shelters and confirming that the identity of any person that a promoter is required to identify to IRS is not privileged.
WHY ESTATE PLANNING MATTERS
  1. You can designate who gets what when you are gone, instead of leaving it to a formula or reducing assets to cash.
  2. You can designate guardians for your minor children.
  3. You can specify exactly who you want to be in charge of distributing your assets.
  4. It can help you minimize court costs and taxes maximizing what you leave to your loved ones.
  5. It can help you distribute your wealth meeting your concerns about the maturity of their dealing with a windfall.
  6. It can help structure your affairs so that a business continues. It is not a substitute for a succession plan, but it can spell out some ideas.
BOND LADDER STRATEGY MIGHT BE RIGHT
JUST FOR GRINS

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