Articles From Jesse T. Coyle

Captive insurance companies—A reassuring way to self-insure By Jesse T. Coyle Trusts and Estates, July 2013 The author, who recently helped to pass North Carolina's Captive Insurance Company law, discusses this unique estate planning vehicle.
Say bye-bye to passive activity losses: A possible past-time for LLCs and LLPs By Jesse T. Coyle Trusts and Estates, January 2010 Limited liability companies (LLCs) and limited liability partnerships (LLPs) are well ingrained as two of the preferred techniques used by estate planning professionals. Both LLCs and LLPs offer significant advantages that many other techniques do not: valuation discounts, retention of control, and tax efficiency. To the delight of those individuals who use LLCs and LLPs in their estate planning work, the perceived tax efficiency of these methods has improved through two recent court cases.  
Choosing a Roth IRA By Jesse T. Coyle Trusts and Estates, July 2009 The ultimate consideration in deciding whether to choose a Traditional or Roth IRA generally becomes whether you would rather pay tax now or later.
A GRAT way to transfer wealth. Well, at least for now… By Jesse T. Coyle Trusts and Estates, July 2009 If you possess assets that are appreciating fast (or at least you think they will), the GRAT is simply one of the most effective ways of transferring value at a low cost. The future of this technique is not clear, however, as proposed legislation could render it ineffective.  
Uncertain times for estate planners: What changes loom for 2009? By Jesse T. Coyle Trusts and Estates, July 2009 Several possible changes that may occur in the very near future pose great uncertainty for estate planners. The biggest uncertainty revolves around the estate tax.
Private annuities By Jesse T. Coyle Trusts and Estates, May 2009 A private annuity can be an effective way of transferring wealth to a family member, freezing the estate, avoiding estate and gift tax, and ensuring a lifetime stream of income.
Estate planning in a low-interest-rate environment By Jesse T. Coyle Trusts and Estates, April 2009 This article discusses the mechanics of techniques such as intra-family loans, SCINs, installment sales to grantor trusts, GRATs, CLATs and charitable gifts of personal residence remainders, and how they flourish in a low-interest environment.
The fine art of fine art investments By Jesse T. Coyle Trusts and Estates, April 2009 Investing in art can be an exciting opportunity for many individuals to make great profit, diversify a portfolio, and to add aesthetic beauty to an individual’s home. But as with all investments, engaging in the collection of art for investment purposes carries its own unique risks that should thoroughly investigated and evaluated.
Ahoy, Ahoy! A Tax Bill on the Horizon By Jesse T. Coyle Trusts and Estates, March 2009 In a bi-partisan effort, U.S. Representatives Mark Kirk (Republican) and Harry Mitchell (Democrat) introduced H..R. 498 ( “Tax Bill”), legislation designed to address the problems with the estate tax and capital gains tax. But in order to become law this bill still has a few significant hurdles to pass.
Bonds and the original issue discount: Easy does it By Jesse T. Coyle Trusts and Estates, February 2009 With the investment landscape changing investors have shown interest in more secure and conservative investment vehicles. Many clients have expressed an interest in bonds. However, the complexity of the varying bond vehicles and the income tax implications is often something that clients fail to understand.  
SCINS, GRATS and IDGTs: Acronyms that present planning opportunities in a low-interest environment By Jesse T. Coyle Trusts and Estates, February 2009 With interest rates at historical lows, several wealth transfer techniques offer high net worth individuals an excellent opportunity to transfer wealth to their descendants at a minimal cost. These techniques benefit from low interest rates. Two sophisticated estate planning techniques that benefit from a low interest rate environment are the SCIN and the GRAT.  
A year-end opportunity to wash your dirty stocks: Harvesting losses with wash sales By David A. Berek & Jesse T. Coyle Trusts and Estates, January 2009 The Internal Revenue Code Section 165(a) permits deductions for any loss sustained during the taxable year and not compensated for by insurance or otherwise. The broad language of Section 165 seemingly allows deductions for almost any type of loss. Logically, the language has of this Section has resulted in abuse, causing Congress to respond by creating limitations on the deductibility of losses. One of the deductions that Congress has disallowed is the deduction for losses resulting from wash sales of stock or securities.  
Year-end tax tips By Jesse T. Coyle Trusts and Estates, January 2009 Before the calendar year ends, consider the following tax planning techniques.

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