The Not-So Basics of Capital Accounts Maintenance

The Not-So Basics of Capital Accounts Maintenance

Although a partnership is the most flexible vehicle for taxpayers seeking non-pro-rata allocations of profit and loss items, for those allocations to be respected by the IRS they must have “economic effect”. This term has often confused taxpayers and their...
Using personal holding companies to defer tax

Using personal holding companies to defer tax

High-net worth individuals (“HNWIs”) seeking to defer taxes on income derived from foreign stocks and foreign or U.S. bonds should consider implementing the structure above. Such a structure will be particularly effective where the investor will not need this money...