Transfer tax opportunities when Mr. Popeil pushes executive compensation through the pasta maker: food for thought or recipe for disater?

Article Abstract:

Executives and highly-compensated employees can realize transfer tax savings in conjunction with their compensation packages. Transfer tax planning techniques can include use of corporate-, partnership-, or limited liability company-based compensation, involving a variety of options, debentures, sharing of partnership profits or capital interests, and vesting schedules. Stock transfers and options, discounting time value of money, tax planning models, and potential IRS problem areas are also discussed.

Estate Planning, Methods, United States, Compensation and benefits, Executives, Executive compensation, Transfer taxes

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Guaranteed payments for the use of capital: schizophrenia in Subchapter K

Article Abstract:

Guaranteed payments for the use of capital (GPUCs) by partnerhsips are taxed in IRC section 707(c) differently from other investments, with some advantages for tax planning and some disadvantages which need to be corrected by legislation. Federal tax law on GPUCs should take a bifurcation approach and split the equity interest of a partner from the GPUC, treating the GPUC as interest on a loan. An alternative to bifurcation would be an approach which emphasizes interest on capital.

Analysis, Investments

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Partner wars: tax planning for acrimonious partnership situations

Article Abstract:

Tax questions which may arise as a result of partnership litigation are reviewed. Tax regulations regarding legal settlements, damage awards, and legal fees paid as a result of such actions are examined. Tax planning issues are discussed.

Legal issues & crime, Government regulation (cont), Government regulation, Management dynamics, Taxes, Legal/Government Regulation, Management, Compromise and settlement, Settlements (Law), Company business management, Damages, Damages (Law), Costs (Law), Legal fees

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