Estate Inclusion: The New Estate Plan, Step-Up

Background The traditional estate planning game has been to: (1) ensure client wishes were achieved by drafting wills and trusts such that the assets within the client’s estate served the intended purposes and landed in the hands of the desired beneficiaries, and (2) minimize or eliminate estate (and generation skipping) taxes. Since 2000, a few…
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Playing with a Loaded Deck: CARDS and the Economic Substance Doctrine

BACKGROUND THE PARTIES On July 2nd, 2018, the Tax Court released its ruling in Roy E. Hahn, et al. v. Comm’r, TC Memo 2018-100. The case revolved around whether the taxpayers were entitled to deduct certain losses from a Custom Adjustable Rate Debt Structure (CARDS) transaction. The primary reason for this article is not to…
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The Marital Partnership, the Joint Return, and the Non-Disregarded Entity

When husband and wife own a partnership together, a common misconception is that because a joint return is filed for the husband and wife, the partnership can be treated as a disregarded entity and not have to file its own return. Unfortunately for some, it is sometimes realized after the reliance on this erroneous fact,…
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Unlocking the HELOC Interest Deductions: Clarifications from the IRS

The IRS published an Information Release on February 21, 2018 clarifying that certain home loan mortgage interest deductions many thought were lost under the new tax act may still be deductible. The Tax Cuts and Jobs Act of 2017 (“TCJA”), which was enacted on December 22, 2017, suspends from 2018 until 2026, any deduction for…
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New website!

It has been a project, but we are happy to announce our website is finally up and going. We intend to add more content regularly.

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[**Practice Alert: Corporate Transparency Act is Here: What You Need to Know**](https://esapllc.com/practice-alert-cta-mar-2024/)
[**Practice Alert: Corporate Transparency Act is Here: What You Need to Know**](https://esapllc.com/practice-alert-cta-mar-2024/)