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The overarching policy of the estate tax regime in the United States can largely be summed up as follows: Assets should be taxed once at each generation.  In developing the sections of the Internal Revenue Code that govern the estate tax, Congress has also made clear that spouses are considered to be in the same generation, regardless of age.  This is grounded in another tenet of U.S. tax policy that treats spouses as one economic unit. Since 1981, the Internal Revenue Code has permitted unlimited, tax-free transfers between spouses.  That same year, Congress also enacted an exception to t...

Market Trends: What You Need to Know As shown in the American Bar Association's Private Target Mergers and Acquisitions Deal Point Studies: Since 2011, the use of after-tax indemnity limitations has steadily decreased, appearing in 32% of deals reviewed in the 2019 study. Notwithstanding potentially limited economic benefits of an after-tax indemnity limitation, these provisions are still seen, though decreasingly so, in M&A transactions. After-tax indemnity limitations grew in prevalence across the first three ABA studies (2007-2011), to a peak of 53% for deals reported in the 2011 study. Ho...

A recent trend in the blockchain business, and particularly among cryptocurrency companies, is to seek tax-exempt status under Section 501(c)(3) of the Internal Revenue Code (the Code)....

To embed, copy and paste the code into your website or blog: Remodeling one’s kitchen is undoubtedly one of the most expensive items on a fixer-upper owner’s budget. The Tax Trotter knows first-hand – she and Mr. Tax Trotter purchased the worst house on the best block 8 years ago and are still renovating it. Multiple cost-saving strategies have been deployed, including buying underpriced mahogany furniture sold on commission to affixing a custom-ordered granite countertop to a set of classic style cream cabinets sourced from IKEA on a savvy friend’s advice. There were some excesses be...

Various 501(c)(3) organizations may pursue charitable activities or operate to pursue altruistic purposes. However, what if such activities or purposes do not fall within the Internal...