IPB TAX, TRUSTS & ESTATES

Follow links below to the IPB Tax, Trusts & Estates Newsletter.

In This Issue:

• Inbound Investments in Light of U.S. Tax Reform – Inbound investors should structure U.S. business interests to take advantage of lower corporate tax rates and the Section 199A pass-through deduction.
• Six "Super" Ideas for Using That "Huge" New Exemption – Clients could plan lifetime gifts to trusts, using the marital deduction at death, retaining a swap power, making a sale, moving assets up a generation, or doing a DAPT to obtain transfer tax, income tax, or basis benefits.
• Practice Note: IRS to Terminate Offshore Voluntary Disclosure Program – U.S. persons with undisclosed offshore assets or income should act before the Offshore Voluntary Disclosure Program expires on September 28, 2018.
• Tax Reform and Private Foundations – Separately computed UBTI for each business line may increase tax liability, and employee fringe benefits will be part of UBTI.
• To Deduct or Not to Deduct? – The Section 67(g) prohibition on miscellaneous itemized deductions will apply to fees for producing or collecting trust and estate income, but whether fees not subject to the 2% floor under Section 67(e) will still be deductible is unclear. 
• IPB in the News