Attorney-at-Law

NO COMMENT

In Uncategorized on 12/30/2015 at 15:49

Peter Reilly, CPA and ace blogger for forbes.com, asked me this afternoon if I meant to comment on Estate of Barbara M. Purdue, Deceased, 2015 T. C. Memo. 249, filed 12/28/15.

I replied that I did not, as the principle that centralized management of assets by family members was a sufficient non-tax reason to avoid the toils of Section 2036(a) was well established. See my blogpost “Flip for FLP,” 2/23/12. The Purdue case adds nothing to that principle.

Mr. Reilly has said that he’ll be commenting on Purdue, wherefore I refer my readers to the Forbes website and Mr. Reilly’s no doubt exhaustive exegesis thereon.

I might have used the Purdue case as a springboard to a discussion of the New York Times’ special report, dated 12/29/15, discussing how the wealthiest have built their own private tax system.

But there was nothing new about round-tripping cash to Bermuda reinsurers to transmute ordinary income into capital gains (it was invented by Lloyds of London in the pre-Thatcher days, to duck Britain’s then-98% top tax bracket).

And the FLP maneuver is standard operating procedure.

The universal life insurance dodge was mentioned, but we knew all about that. See my blogpost “Keep Your Hand Upon the Dollar,” 6/30/15.

The annuity-for-assets dodge (see my blogpost “No’ Deid Yet,” 2/7/13) was not touched upon, but I’m sure the reporter was overwhelmed with the clichéd dodges aforementioned.

I could here launch into a diatribe, but I have done so elsewhere.

I’ll spare my readers.

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