Probate & Estate Planning

High net worth second marriage couple from Phoenix desired to review and update their estate plan, which included bequests of sole and separate property to each spouse’s children.    DeAngelis Legal reviewed the couple’s current estate plan, worked with their investment advisor and accountant to identify and resolve a variety of income tax, estate tax and logistical issues and prepared updated estate plan documents.
The post January 2024 High Net Worth Estate Planning appeared first on DeAngelis Legal.
Continue Reading January 2024 High Net Worth Estate Planning

Successor trustee desired assistance with the administration of a simple trust. During administration, the beneficiaries of the trust requested that the trustee modify the provisions of the trust, including altering the remainder beneficiaries, one of which was an incapacitated adult. DeAngelis Legal provided proper notice to creditors and beneficiaries, advised the trustee as to permissible alternatives during administration and reviewed and revised the non-judicial settlement agreement implementing the agreed upon solution. The end result permitted the trustee to liquidate the principal of the trust early and distribute the incapacitated adult’s share to a special needs trust for his benefit.
The
Continue Reading January 2024 Trust Administration

The use of a holding company offers an extra layer of legal separation between you and your business entities and assets.

Over the years, numerous strategies have been developed to help business owners, professionals, and owners of vulnerable assets protect their interests against litigation, creditor claims, and other future legal and financial threats.

In

our asset protection practice

, we utilize a variety of legal structures, special trusts, and other planning vehicles to help our clients achieve their legal and financial goals and achieve peace of mind.

That assortment of asset protection options includes a long-standing, battle-tested option: the

holding
Continue Reading Asset Protection: Should a Holding Company Own Your Business?

Information in this release concerning the case is posted with the client’s permission.

Phoenix, AZ (January, 16, 2023) – Frazer Ryan Goldberg & Arnold, LLP, a leading Arizona-based law firm, is pleased to announce that on January 12, 2024, senior partner Brandon Keim and attorneys Trisha Farrow and Ida Araya prevailed in the United States District Court in a jury trial, obtaining a total victory for their client, Michael Quiel, by defending against the United States’ claim that he owed $2.2 million in penalties for failing to report foreign bank accounts on an FBAR form (FinCEN Form 114) for 2007
Continue Reading FRGA Attorneys Win Total Defense Verdict Against the IRS and United States in Jury Trial Regarding Foreign Bank Accounts Claim

In the January/February 2024 issue of

AZ Business

magazine, T.J. Ryan and Lisa Reilly Payton are featured in the

“Top 100 Lawyers in Arizona.”

Click here

to read more on pages 96 and 97 of the digital issue.
Continue Reading T.J. Ryan and Lisa Reilly Payton are featured in the 2024 "Top 100 Lawyers in Arizona" by AZ Business Magazine

Information in this release concerning the case is posted with the client’s permission.

Phoenix, AZ (January, 16, 2023) – Frazer Ryan Goldberg & Arnold, LLP, a leading Arizona-based law firm, is pleased to announce that on January 12, 2024, senior partner Brandon Keim and attorneys Trisha Farrow and Ida Araya prevailed in the United States District Court in a jury trial, obtaining a total victory for their client, Michael Quiel, by defending against the United States’ claim that he owed $2.2 million in penalties for failing to report foreign bank accounts on an FBAR form (FinCEN Form 114) for 2007
Continue Reading PRESS RELEASE: FRGA Attorneys Win Total Defense Verdict Against the IRS and United States in Jury Trial Regarding Foreign Bank Accounts Claim

Ultra high net worth couple acquired the majority stake in a foreign entity holding real estate operated by the minority party. As is often the case in these arrangements, conflicts arose between the parties regarding the ownership, control and management of the property. Complicating matters were incomplete financial records and communication issues. DeAngelis Legal worked with the couple, their US tax team, foreign counsel, the entity’s foreign accountant and the third party to reach and document a resolution between the parties.
The post December 2023 Mergers and Acquisitions appeared first on DeAngelis Legal.
Continue Reading December 2023 Mergers and Acquisitions

Estate Planning Update
January 2024
1. 2024 Annual Gift Tax Exclusion: increased to $18,000 per donor, per donee.
2. 2024 Gift and Estate Tax Exemption: increased to $13,610,000 per donor through 2025, see #6, an increase of $690,000.
3. Marital Deduction for Transfers to U.S. Spouse: remains unlimited.
4. 2023 Generation Skipping Tax Exemption: increased to $13,610,000 per donor through 2025, see #6.
5. Top rate for Federal Estate, Gift and Generation Skipping Taxes: 40%.
6. National Topics:
a. The current Gift and Estate Tax Exemption is doubled to get to the amounts set forth above. It is anyone’s guess
Continue Reading January 2024 Estate Planning Update

A new federal law requires most legal entities to report specific information about the business and its owners. This article provides multiple updates that warrant business owners’ attention.

The CTA is a provision of the Anti-Money Laundering Act, which is part of a federal effort to combat shell corporations, LLCs and other entities that engage in illegal money laundering and other criminal financial activities.

This article provides a general overview and multiple updates from our September 2023 article. This version includes the following changes:

  • The Beneficial Ownership Information

    reporting portal

    is ready to use.

  • FinCEN has published the

    Small Entity


Continue Reading UPDATE: Corporate Transparency Act Update: effective date pushed back to January 1, 2024

Welcome to 2024 and the Corporate Transparency Act (CTA) – a new federal law that requires most small businesses to file a new report with the Treasury Department.

A few things you should know about the Act:

  • Who Must Report?

     The reporting requirements generally apply to most closely held corporations, LLCs, and similar entities. Banks, securities firms, publicly traded companies, and certain other entities are exempt.

  • What Must be Reported?

     You must disclose to FinCEN private information about your company’s beneficial owners, including full legal names, residential addresses, dates of birth, and identification numbers.

  • What Are the Consequences of Non-compliance?


Continue Reading Corporate Transparency Act imposes new reporting requirements on small businesses

Beginning January 1, 2024, the US Corporate Transparency Act (CTA) will require corporations, limited liability companies, limited partnerships, trusts and other similar entities to disclose beneficial ownership information to the Financial Crimes Enforcement Network (FinCEN), a bureau within the US Department of the Treasury. The CTA aims to enhance financial transparency and strengthen anti-money laundering efforts by detecting, preventing, and punishing terrorism, money laundering, and other misconduct through business entities.
Entities that were formed before January 1, 2024, will have to report by December 31, 2024.  Any new company formed after January 1, 2024, will need to report within 30
Continue Reading The Corporate Transparency Act (CTA) – New Year. New Requirements.

After graduating from Duke with a degree in Physics in 1961, Koskinen set out to Yale School of Law (“I decided that people were more interesting than electrons”). Thirty-seven years later — inspired by his years at Duke, keen human interest, and desire to preserve his children’s inheritance — Koskinen set up a charity lead annuity trust to benefit the university. While endowment programs have long sought out generous contributions from donors, Koskinen was ahead of his time in using a CLAT to provide exponential yearly benefits to both donor and institution. Koskinen’s CLAT used the appreciation from his invested
Continue Reading How a former IRS boss optimizes his charitable trust to support his alma mater – and give assets to his children tax-free

On December 19, the Internal Revenue Service announced it will provide $1 billion in penalty relief for taxpayers to whom the IRS did not send automated collection-reminder notices during the pandemic.

The IRS is waiving the failure-to-pay penalties for eligible taxpayers affected by this situation for tax years 2020 and 2021. The IRS estimates that five million tax returns, filed by 4.7 million individuals, businesses, trusts, estates and tax-exempt organizations, are eligible for the penalty relief.

The relief is automatic, and eligible taxpayers do not need to take any action to get it. Eligible taxpayers who already paid their full
Continue Reading IRS announces penalty relief for nearly 5 million taxpayers

Co-owners of successful Arizona based closely held business disagreed about the entity’s future, its ownership and its management.  DeAngelis Legal reviewed the parties’ shareholder agreement and other corporate documents, advised the owner regarding various exit strategies and negotiated and implemented the ultimate sale of a non-controlling interest to a third party.
The post November 2023 Mergers and Acquisitions appeared first on DeAngelis Legal.
Continue Reading November 2023 Mergers and Acquisitions