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	<title>AdvisorFYI</title>
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	<description>Industry Intelligence for Savvy Advisors</description>
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		<title>Financial Careers and Strategy &#8211; The Art of Self Promotion &#8211; By: George Mentz, JD MBA CWM</title>
		<link>http://www.advisorfyi.com/2012/04/financial-careers-and-strategy-the-art-of-self-promotion/</link>
		<comments>http://www.advisorfyi.com/2012/04/financial-careers-and-strategy-the-art-of-self-promotion/#comments</comments>
		<pubDate>Mon, 30 Apr 2012 21:19:17 +0000</pubDate>
		<dc:creator>George Mentz JD, MBA, CWM, MFP - International Lawyer and Award Winning Author</dc:creator>
				<category><![CDATA[Uncategorized]]></category>

		<guid isPermaLink="false">http://www.advisorfyi.com/?p=2829</guid>
		<description><![CDATA[Over the years, I have studied the art of promotion.  Unfortunately, if you don't market yourself, nobody may ever know about your attributes of  excellence.
 
I distinctly remember reading the book Brag by Peggy Klaus.  This bestseller discussed the art of self promotion without over-doing it and the full title of the book is "Brag!: The Art of Tooting Your Own Horn without Blowing It."  In her book, she states, " When done with grace and style, bragging promotes your best asset-you!."]]></description>
			<content:encoded><![CDATA[<p><strong>Financial Careers and Career Strategy &#8211; The Art of Promotion</strong> by George Mentz, JD MBA CWM</p>
<p>Over the years, I have studied the art of promotion.  Unfortunately, if you don&#8217;t market yourself, nobody may ever know about your attributes of  excellence.</p>
<p>I distinctly remember reading the book Brag by Peggy Klaus.  This bestseller discussed the art of self promotion without over-doing it and the full title of the book is &#8220;Brag!: The Art of Tooting Your Own Horn without Blowing It.&#8221;  In her book, she states, &#8221; When done with grace and style, bragging promotes your best asset-you!.&#8221;</p>
<p>This reminds me of an interview that I had years ago with a Wall Street Firm executive .  The executive of an NYSE traded company kept asking me what else I had achieved and what other credentials I had earned.  Later, I discovered that the interviewer  was looking for reasons to give the job to me over another similarly qualified candidate.  When I told the executive that I also had membership in another organization and credentials from a relevant industry institution, he was sold, and I got the job.  The moral of the story is to keep adding feathers to your cap and as Dr. Covey of the famous book &#8220;7 Habits of Highly Successful People&#8221; promotes, keep sharpening the saw.</p>
<p>Your  resume has pertinent sections for degrees, training, certificates, diplomas, memberships, charitable endeavors, designations, awards and other distinctions.  In the professional ethics courses that I teach, many students have difficulty legitimately claiming their skills, experience, or attributes.  For example, many students do not add relevant summer work to the totality of their work experience. For whatever reason, many applicants  do not consider part-time work or volunteer work part of their resume&#8217;s experience; however, most job candidates are smart enough to add this type of experience to their job applications. The bad news is that many competent applicants lose out because of this type of hyper-humbleness.</p>
<p>In the end, each of us should take a hard look at winning resumes styles and model ours to mirror what works.  We should ethically add to our resume anything that helps sell our abilities to get that job or customer.  Also, we can join industry organizations, join college organizations before or even after graduating, volunteer in an area of interest to gain experience, take courses online, earn certificates or supplemental diplomas, learn another language, and even engage charity to better ourselves.</p>
<p>Self promotion also includes your style and methods when dealing with customers.  I remember one company president who said that customers shop several providers before picking his firm.  He told me that all of his brochures illuminated some  extra accolades that his company had achieved  and he also provided one or two extra  documents  to each potential client explaining the benefits and safety  of doing business with his company.  Invariably, this extra consideration in the interview paid off and many clients came to his firm because of the value added attention to detail.</p>
<p>If you read Robert Green&#8217;s &#8220;The 48 Laws of Power&#8221;, you will find that it takes skill and mastery to negotiate the kings court while moving your status upward. In the same way, the job seeker must treat  each decision maker with respect while letting them know how you will help them with their success and the company success.</p>
<p>Remember, learn to promote yourself and guard your reputation.  Practice interviewing, discuss with another person what should be included on your resume or your sales pitch, and most of all, learn how to convey your best qualifications, ability to serve,  and your relevant experience.</p>
<p>*George Mentz can be retained as a keynote speaker for your events at: www.gmentz.com</p>
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		<title>Wealth Management &#8211; Tax Time and Beyond</title>
		<link>http://www.advisorfyi.com/2012/04/wealth-management-tax-time-and-beyond/</link>
		<comments>http://www.advisorfyi.com/2012/04/wealth-management-tax-time-and-beyond/#comments</comments>
		<pubDate>Wed, 11 Apr 2012 03:16:18 +0000</pubDate>
		<dc:creator>George Mentz JD, MBA, CWM, MFP - International Lawyer and Award Winning Author</dc:creator>
				<category><![CDATA[Uncategorized]]></category>
		<category><![CDATA[asset management]]></category>
		<category><![CDATA[certified]]></category>
		<category><![CDATA[chartered]]></category>
		<category><![CDATA[Estates]]></category>
		<category><![CDATA[financial analyst]]></category>
		<category><![CDATA[financial planning]]></category>
		<category><![CDATA[Investment management]]></category>
		<category><![CDATA[market technician]]></category>
		<category><![CDATA[planning]]></category>
		<category><![CDATA[Retirement]]></category>
		<category><![CDATA[Taxation]]></category>
		<category><![CDATA[taxes]]></category>
		<category><![CDATA[trusts]]></category>
		<category><![CDATA[wealth management]]></category>

		<guid isPermaLink="false">http://www.advisorfyi.com/?p=2821</guid>
		<description><![CDATA[As a wealth management consultant and professor for over a decade, it is that time again to file our taxes.  With tax filings, we must document our income, expenses, deductions, exemptions, retirement contributions and so forth.  Some of us must file our taxes for partnerships or corporations.
 
Wealth management comprises various subjects including: Economics, Banking, Investments, Risk Management, Investment/Asset Management, Estate Succession, Taxation, and Trust Planning  and Retirement  Planning.]]></description>
			<content:encoded><![CDATA[<p>As a wealth management consultant and professor for over a decade, it is that time again to file our taxes.  With tax filings, we must document our income, expenses, deductions, exemptions, retirement contributions and so forth.  Some of us must file our taxes for partnerships or corporations.</p>
<p>Wealth management comprises various subjects including: Economics, Banking, Investments, Risk Management, Investment/Asset Management, Estate Succession, Taxation, and Trust Planning  and Retirement  Planning.</p>
<p>Many of us simply receive W-2 and employment income and traditional company benefits  primarily, but others who are self-employed or contractors are doing their best to utilize the system to declare income, pay for insurance, take mortgage deduction and so forth.</p>
<p>The good news is that that the tax code has become more amicable to the self employed over the last decade.  Self employed individuals are able to write off or deduct more of their health care expenses while also setting aside more money pre-tax into their self directed retirement accounts.</p>
<p>Here are some thoughts related to Wealth Management 2012</p>
<p>Investments: While we are not sure what will happen with taxes going forward, several of today&#8217;s tax rates on income such as dividends and long-term capital gains are reasonable.  If they go up, many people may sell out of dividend stocks or other related holdings.  Dividend stocks have been particularly popular for retirees and those who don&#8217;t want CDs with the rates so low.</p>
<p>Thus, dividend stocks have been the alternative for income producing investments because the tax rates are at 15%.  Overall, if income taxes go up on dividend stocks at this time, the hardest hit may be seniors and those who live on a fixed income.</p>
<p>Retirement and Education: In light of the present  situation, we hope you are able to maximize your contributions to your retirement before April 15th each year.  Also, setting aside money in a 529 plan is a good way to fund a child or grandchild&#8217;s education for the future.  The annual gifting rules and estate and gift tax rules allow you to gift cash to others during life or at death.  Therefore, now may be a good time to consider large gifts due to the generous estate &amp; gift tax exemption for 2012.</p>
<p>Estates and Succession:  As for estate taxes, those rates right now are the most generous ever.  However, the large exemption may be reduced again to the Clinton era rates if nothing is done by Congress before 2013.</p>
<p>The other major estate management  issues are succession documents.   Do you have a valid will?  Do you have health care directives?  Have you considered limited powers of attorney for your financial affairs or health care affairs?  Have you arranged for the guardianship of your children if something happens to you?  All of these issues can be dynamic and very important?</p>
<p>Insurance: Other topics are risk management related.  Do you have proper life, health, and home insurance?  Have you considered an umbrella policy or disability policy?  Again, protecting yourself and your family in this way is imperative.  However, you must remember that insurance contracts have beneficiaries and that each policy can have primary beneficiaries or secondary beneficiaries. Further, these assets are not controlled by your will and the beneficiary receives regardless of what your will says. Providing the policy numbers and information to your loved ones may also be a good exercise.</p>
<p>Banking and Investment Accounts: Additionally, if you have bank or brokerage accounts, you should consider listing your spouse or loved one as person who receives the account upon death.  TOD &#8220;Transfer on Death&#8221; and POD &#8220;Payable on Death&#8221; accounts are typical choices for your accounts and this allows a loved one to have access to cash immediately if something happens to you.  Sometimes, rolling over or consolidating accounts is a great exercise so as to help create a better view of the totality of your investments.</p>
<p>Taxation: The IRS has a tax tips section which is interesting and resourceful.  Moreover, there are many great tax software  programs out there to chose from that you can use privately on your computer.  Thus, with good information coming from the Treasury Department and quality software, all of us have a fair opportunity to get our tax paperwork done on time.</p>
<p>Economics: Keep in mind that there has been a number of economic cycles in the last 20 years in the USA and Internationally.   That means that we should all keep an eye on our risk tolerance and our investing  time horizon.  When you are getting closer to retirement, you should be moving out of riskier investments and into more stable investments or stocks with less volatility if possible.  Other related problems such as an election year and global debt crisis issues domestically and abroad are also now part of the macro-economic effects.</p>
<p>In the end, most people are concerned with financial security.  During our earning years,  all of us want to work in a labor of love, earn what we can, protect our children and retirement, and worry about taxes  later.  In the end, the key is doing what you want to do, and have the experts handle your legal, tax and wealth management for you.</p>
<p>*No investment, legal or tax advice is intended to be given herein.  Please see a licensed professional before making any important decision.</p>
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		<title>Tax Tips &#8211; Extensions, Credit, and More Time</title>
		<link>http://www.advisorfyi.com/2012/04/tax-tips-extensions-and-more-time/</link>
		<comments>http://www.advisorfyi.com/2012/04/tax-tips-extensions-and-more-time/#comments</comments>
		<pubDate>Wed, 04 Apr 2012 23:13:54 +0000</pubDate>
		<dc:creator>George Mentz JD, MBA, CWM, MFP - International Lawyer and Award Winning Author</dc:creator>
				<category><![CDATA[Uncategorized]]></category>
		<category><![CDATA[extenstion]]></category>
		<category><![CDATA[IRA]]></category>
		<category><![CDATA[penalties]]></category>
		<category><![CDATA[Savvings]]></category>
		<category><![CDATA[Tax]]></category>

		<guid isPermaLink="false">http://www.advisorfyi.com/?p=2809</guid>
		<description><![CDATA[Tips for Taxpayers Who Can't Pay Their Taxes on Time  - If you owe tax with your federal tax return, but can't afford to pay it all when you file, the IRS wants you to know your options and help you keep interest and penalties to a minimum. ]]></description>
			<content:encoded><![CDATA[<p><strong>Tips for Taxpayers Who Can&#8217;t Pay Their Taxes on Time</strong></p>
<p>If you owe tax with your federal tax return, but can&#8217;t afford to pay it all when you file, the IRS wants you to know your options and help you keep interest and penalties to a minimum.</p>
<p>Here are five tips:</p>
<p>File your return on time and pay as much as you can with the return. These steps will eliminate the late filing penalty, reduce the late payment penalty and cut down on interest charges. For electronic and credit card options for paying see www.irs.gov. You may also mail a check payable to the United States Treasury.</p>
<p>Consider obtaining a loan or paying by credit card. The interest rate and fees charged by a bank or credit card company may be lower than interest and penalties imposed by the Internal Revenue Code.</p>
<p>Request an installment payment agreement. You do not need to wait for IRS to send you a bill before requesting a payment agreement. Options for requesting an agreement include:</p>
<p>•    Using the Online Payment Agreement application at www.irs.gov, and<br />
•    Completing and submitting IRS Form 9465-FS, Installment Agreement<br />
Request, with your return.</p>
<p>IRS charges a user fee to set up your payment agreement. See www.irs.gov or the installment agreement request form for fee amounts.</p>
<p>Request an extension of time to pay. For tax year 2011, qualifying individuals may request an extension of time to pay and have the late payment penalty waived as part of the IRS Fresh Start Initiative. To see if you qualify visit www.irs.gov and get form 1127-A, Application for Extension of Time for Payment. But hurry, your application must be filed by April 17, 2012.</p>
<p>If you receive a bill from the IRS, please contact us immediately to discuss these and other payment options. Ignoring the bill will only compound your problem and could lead to IRS collection action.</p>
<p>If you can’t pay in full and on time, the key to minimizing your penalty and interest charges is to pay as much as possible by the tax deadline and the balance as soon as you can. For more information on the IRS collection process go to www.irs.gov  or see IRSVideos.gov/OweTaxes .</p>
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		<title>Statutory Employees: Full-time Life Insurance Salespeople</title>
		<link>http://www.advisorfyi.com/2012/03/statutory-employees-full-time-life-insurance-salespeople/</link>
		<comments>http://www.advisorfyi.com/2012/03/statutory-employees-full-time-life-insurance-salespeople/#comments</comments>
		<pubDate>Thu, 22 Mar 2012 11:30:58 +0000</pubDate>
		<dc:creator>Prof. William Byrnes</dc:creator>
				<category><![CDATA[Uncategorized]]></category>
		<category><![CDATA[1099]]></category>
		<category><![CDATA[independent contractor]]></category>

		<guid isPermaLink="false">http://www.advisorfyi.com/?p=96</guid>
		<description><![CDATA[Discusses the definition of Statutory Employees and how the term relates to insurance agents.  Issues surrounding employees and independent contractors are further complicated by legislation affecting life-insurance and annuity salespeople.]]></description>
			<content:encoded><![CDATA[<p><em>Why is this Topic Important to Financial Professionals? General classification and taxation of insurance professionals is governed by statute.  Therefore, a basic discussion of the law as it applies to insurance agents and tax is below. </em><em> </em></p>
<p>Just because common law classifications would allow for compensation as an independent contractor, doesn’t mean Congress agrees. An individual who meets the legal definition of an independent contractor may still be considered an “employee” for tax purposes.  Generally, these “independent contractors” that are treated as “employees” are given the name “Statutory Employees”.  As the name implies, Congress created a law that states some individuals who would normally be considered under common law as independent contractors are treated as employees for tax purposes.  Among the categorization of “Statutory Employees”, according to the Code is “full-time life insurance salesman.” <a href="file:///E:/Gd/Nat%20Under/Blog%20Final/08_26_10_AdvisorFYI_blog%20%5bStatutory%20Employes%20Life%20Insurance%20Salespeoplei%5d-9.doc#_ftn1">[1]</a></p>
<p>A full-time life insurance salesman means “[a]n individual whose entire or principal business activity is devoted to the solicitation of life insurance or annuity contracts, or both, primarily for one life insurance company”.<a href="file:///E:/Gd/Nat%20Under/Blog%20Final/08_26_10_AdvisorFYI_blog%20%5bStatutory%20Employes%20Life%20Insurance%20Salespeoplei%5d-9.doc#_ftn2">[2]</a> The Treasury Regulations state that a full time life insurance salesman “ordinarily uses the office space provided by the company or its general agent, and stenographic assistance, telephone facilities, forms, rate books, and advertising materials are usually made available to him without cost.” <a href="file:///E:/Gd/Nat%20Under/Blog%20Final/08_26_10_AdvisorFYI_blog%20%5bStatutory%20Employes%20Life%20Insurance%20Salespeoplei%5d-9.doc#_ftn3">[3]</a></p>
<p>On the contrary, an individual is not considered a full time life insurance salesman when he “is engaged in the general insurance business… the individual&#8217;s principal business activity” is not the, “solicitation of life insurance or annuity contracts, or both, for one company”.<a href="file:///E:/Gd/Nat%20Under/Blog%20Final/08_26_10_AdvisorFYI_blog%20%5bStatutory%20Employes%20Life%20Insurance%20Salespeoplei%5d-9.doc#_ftn4">[4]</a> Likewise, “any individual who devotes only part time to the solicitation of life insurance contracts, including annuity contracts, and is principally engaged in other endeavors, is not a full-time life insurance salesman.” <a href="file:///E:/Gd/Nat%20Under/Blog%20Final/08_26_10_AdvisorFYI_blog%20%5bStatutory%20Employes%20Life%20Insurance%20Salespeoplei%5d-9.doc#_ftn5">[5]</a> Also, some producer groups have contractual relationships with multiple insurance companies, so life-insurance salespeople are sometimes able to sell products for more than one company, generally excluding them from statutory employee definition.</p>
<p>What does it mean to be a statutory employee?  As has been discussed earlier this week, the tax treatment of the two dissimilar arrangements is significantly different.  On the one hand, an employee, including statutory employees, will file for withholding of federal income taxes on wages as well as withholding for Medicare and Social Security taxes.  Employees also are not considered to be in a trade or business.  Generally, independent contractors operate as sole-proprietors or some incorporated or limited liability business structure.  Meeting the definition of a trade or business, generally, these individuals will have gain or loss treatment in relation to their income as a tax structure.</p>
<p>Other examples of statutory employees include:<a href="file:///E:/Gd/Nat%20Under/Blog%20Final/08_26_10_AdvisorFYI_blog%20%5bStatutory%20Employes%20Life%20Insurance%20Salespeoplei%5d-9.doc#_ftn6">[6]</a></p>
<ul>
<li>“A driver who distributes      beverages (other than milk) or meat, vegetable, fruit, or bakery products;      or who picks up and delivers laundry or dry cleaning, if the driver is      [an] agent or is paid on commission.</li>
</ul>
<ul>
<li>“A      full-time traveling or city salesperson who works on your behalf and turns      in orders to you from wholesalers, retailers, contractors, or operators of      hotels, restaurants, or other similar establishments. The goods sold must      be merchandise for resale or supplies for use in the buyer’s business      operation. The work performed for you must be the salesperson&#8217;s principal      business activity.</li>
</ul>
<p>For a detailed analysis regarding the tax treatment of life insurance agent, see Tax Facts <a href="http://www.advisorfx.com/articles/nuco-article.aspx?filename=0361-00-tf1&amp;section=&amp;subsection=" target="_blank">Q 361. Who is an owner-employee for purposes of the qualification requirements</a>?</p>
<p><em>We invite your questions and comments by posting them below, or by calling the <a href="http://www.advisorfyi.com/about/" target="_blank">Panel of Experts</a>.</em></p>
<hr size="1" /><a href="file:///E:/Gd/Nat%20Under/Blog%20Final/08_26_10_AdvisorFYI_blog%20%5bStatutory%20Employes%20Life%20Insurance%20Salespeoplei%5d-9.doc#_ftnref1">[1]</a> 26 U.S.C.A. § 3121(d)(3)(b)</p>
<p><a href="file:///E:/Gd/Nat%20Under/Blog%20Final/08_26_10_AdvisorFYI_blog%20%5bStatutory%20Employes%20Life%20Insurance%20Salespeoplei%5d-9.doc#_ftnref2">[2]</a> 26 C.F.R. § 31.3121(d)-1</p>
<p><a href="file:///E:/Gd/Nat%20Under/Blog%20Final/08_26_10_AdvisorFYI_blog%20%5bStatutory%20Employes%20Life%20Insurance%20Salespeoplei%5d-9.doc#_ftnref3">[3]</a> Id.</p>
<p><a href="file:///E:/Gd/Nat%20Under/Blog%20Final/08_26_10_AdvisorFYI_blog%20%5bStatutory%20Employes%20Life%20Insurance%20Salespeoplei%5d-9.doc#_ftnref4">[4]</a> Id.</p>
<p><a href="file:///E:/Gd/Nat%20Under/Blog%20Final/08_26_10_AdvisorFYI_blog%20%5bStatutory%20Employes%20Life%20Insurance%20Salespeoplei%5d-9.doc#_ftnref5">[5]</a> Id.</p>
<p><a href="file:///E:/Gd/Nat%20Under/Blog%20Final/08_26_10_AdvisorFYI_blog%20%5bStatutory%20Employes%20Life%20Insurance%20Salespeoplei%5d-9.doc#_ftnref6">[6]</a> Internal Revenue Service Publication 15-A (2010).  Page 4.</p>
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		<title>Valuation Discounts: Only for a Bona Fide Business</title>
		<link>http://www.advisorfyi.com/2012/03/valuation-discounts-only-for-a-bona-fide-business/</link>
		<comments>http://www.advisorfyi.com/2012/03/valuation-discounts-only-for-a-bona-fide-business/#comments</comments>
		<pubDate>Tue, 20 Mar 2012 12:00:58 +0000</pubDate>
		<dc:creator>Prof. William Byrnes</dc:creator>
				<category><![CDATA[Uncategorized]]></category>
		<category><![CDATA[accounting]]></category>
		<category><![CDATA[Business]]></category>
		<category><![CDATA[Internal Revenue Service]]></category>
		<category><![CDATA[Law]]></category>
		<category><![CDATA[Opportunities]]></category>
		<category><![CDATA[Services]]></category>
		<category><![CDATA[Tax]]></category>
		<category><![CDATA[United States]]></category>

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		<description><![CDATA[A recent U.S. District Court case, Fisher v. U.S., reminds us that times have changed - placing assets in a business entity is no longer enough to justify a valuation discount—the entity must be run like a business to justify the discount.  ]]></description>
			<content:encoded><![CDATA[<p>Valuation discounts are increasingly challenged by the IRS. Gone are the days when assets could be dropped into a family limited partnership with some transfer restrictions and forgotten about until a valuation discount was needed to reduce a gift or estate tax bill.  A recent U.S. District Court case, <em>Fisher v. U.S</em>., reminds us that times have changed.  Often, placing assets in a business entity is no longer enough to justify a valuation discount—the entity must be run like a business to justify the discount.   Read the analysis by our experts <a href="http://www.advisorfyi.com/about/" target="_self">Robert Bloink and William Byrnes</a> located at AdvisorFX Journal <a href="http://www.advisorfx.com/articles/fc090110-m.aspx?action=16" target="_blank">Valuation Discounts: Only for a Bona Fide Business</a></p>
<p>For some good news about valuation discounts, see our article in AdvisorFX Advisor’s Journal on the <a href="http://www.advisorfx.com/articles/fc080110-i.aspx" target="_blank"><em>Jensen</em> case</a>.</p>
<p>From a tax perspective see Tax Facts <a href="http://www.advisorfx.com/tax-facts/Transfer%20Taxation/Valuation/0613-00-tf1.aspx?action=72" target="_blank">Q 613. How is a closely held business interest valued for federal estate tax purposes?</a></p>
<p>After reading the analysis, we invite your questions and comments by posting them below, or by calling the <a href="http://www.advisorfyi.com/about/" target="_blank">Panel of Experts</a><em>.</em></p>
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		<title>NAIC Reviews Hybrid Annuities to Ensure Meaningful Guaranteed Income Benefit</title>
		<link>http://www.advisorfyi.com/2012/03/naic-reviews-hybrid-annuities-to-ensure-meaningful-guaranteed-income-benefit/</link>
		<comments>http://www.advisorfyi.com/2012/03/naic-reviews-hybrid-annuities-to-ensure-meaningful-guaranteed-income-benefit/#comments</comments>
		<pubDate>Fri, 16 Mar 2012 12:00:51 +0000</pubDate>
		<dc:creator>Benjamin Terner</dc:creator>
				<category><![CDATA[Uncategorized]]></category>

		<guid isPermaLink="false">http://www.advisorfyi.com/?p=2804</guid>
		<description><![CDATA[Hybrid income annuity products can be a great way to provide clients with a stream of income during retirement, especially when they offer guaranteed lifetime withdrawal benefits (GLWB). Despite this, there are a number of reasons why clients may continue to resist locking their funds into an annuity. Typically, they worry about losing control of [...]]]></description>
			<content:encoded><![CDATA[<p>Hybrid income annuity products can be a great way to provide clients with a stream of income during retirement, especially when they offer guaranteed lifetime withdrawal benefits (GLWB). Despite this, there are a number of reasons why clients may continue to resist locking their funds into an annuity. Typically, they worry about losing control of their retirement savings, or an insurance company’s failure to continue annuity payments should they die earlier than expected. The market turmoil of the past few years has generated an additional concern about the financial stability of the companies issuing annuity contracts. A recent National Association of Insurance Commissioners (NAIC) Life Insurance and Annuities Committee meeting should lead to new regulations that will clarify and conform hybrid income annuities in order to make them much easier to sell.</p>
<p><strong>What Is a Hybrid Income Annuity?</strong></p>
<p>Hybrid income annuity products are annuities that are combined with a different type of annuity within the same annuity contract. For example, a contingent deferred annuity (CDA) is an annuity that guarantees lifetime payments based on the value of the assets in the annuity account. Income payments are conditional upon the owner’s survival and the depletion of the assets in the account. Often, a GLWB rider is attached to the annuity to provide lifetime income payments that <em>begin</em> if there is a depletion or change in value of the annuity account’s assets. The addition of the GLWB rider is what makes the annuity a hybrid.</p>
<p>Synthetic hybrid income annuities, which are hybrid income annuities where the assets in the account are not owned by the insurer, are also being investigated, and would be subject to any new regulation.</p>
<div id="_mcePaste">Read this complete analysis of the impact at <a href="http://www.advisorfx.com">AdvisorFX</a> (sign up for a free trial subscription with full access to all of the planning libraries and client presentations if you are not already a subscriber).</div>
<p>For previous coverage of the guaranteed lifetime withdrawal benefits in Advisor’s Journal, see <a href="http://www.advisorfx.com/articles/fc100110-h.aspx?action=16" target="_new">More Consumers Buy Guaranteed Living Benefits Rider.</a></p>
<p>For in-depth analysis of the different types of annuity product, see Advisor’s Main Library: <a href="http://www.advisorfx.com/articles/f22-2_1_13_3790.aspx?action=13" target="_new">E—Annuities.</a></p>
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		<title>Independent Contractors Tax and Reporting Issues</title>
		<link>http://www.advisorfyi.com/2012/03/independent-contractors-tax-and-reporting-issues/</link>
		<comments>http://www.advisorfyi.com/2012/03/independent-contractors-tax-and-reporting-issues/#comments</comments>
		<pubDate>Wed, 14 Mar 2012 11:30:42 +0000</pubDate>
		<dc:creator>Prof. William Byrnes</dc:creator>
				<category><![CDATA[Uncategorized]]></category>
		<category><![CDATA[deductions]]></category>
		<category><![CDATA[income tax]]></category>
		<category><![CDATA[independent contractor]]></category>

		<guid isPermaLink="false">http://www.advisorfyi.com/?p=94</guid>
		<description><![CDATA[Considers the proper classification of employees versus independent contractors and examines the tax and reporting considerations of independent contractors as they relate to self employed individuals]]></description>
			<content:encoded><![CDATA[<p><em>Why is this Topic Important to Financial Professionals:  A general understanding of classification of employees versus independent contractors will not only save your client aggravation, but could also avoid additional taxes and penalties.  In addition, the tax consequences of this determination can be far reaching, and an understanding of the concepts of income and types of allowable deductions can help enable more comprehensive planning for the Financial professional and clients.    <strong> </strong></em></p>
<p>As a general rule, independent contractors compensation is reported through Form 1099-MISC.  In determining net income of the sole proprietor or corporation, one will usually factor income and expenses.  Income in this context is included in Internal Revenue Code Section 61 “Gross Income” which includes “all income from whatever source derived,” including “compensation for services, [and] fees”.<a href="http://www.advisorfyi.com/wp-admin/post.php?action=edit&amp;post=94#_ftn1">[1]</a> Expenses or deductions from gross income for a trade or business are determined using Section 162 of the Code which states that a deduction may be taken for “all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business”.<a href="http://www.advisorfyi.com/wp-admin/post.php?action=edit&amp;post=94#_ftn2">[2]</a></p>
<p>Some expenses that the trade or business may incur include, but are not limited to: <a href="http://www.advisorfyi.com/wp-admin/post.php?action=edit&amp;post=94#_ftn3">[3]</a></p>
<ul>
<li>cost of goods sold</li>
<li>compensation</li>
<li>salaries and wages</li>
<li>repairs and maintenance</li>
<li>bad debts</li>
<li>rents</li>
<li>depreciation</li>
<li>taxes</li>
<li>travel</li>
<li>interest, and</li>
<li>advertising</li>
</ul>
<p>To arrive at net taxable income, expenses are generally deducted from gross income.   The taxpayer can then determine the tax liability using income and percentage charts provided by the Internal Revenue Service.</p>
<p>The IRS states “Self-Employed” individuals or those who carry “on a trade or business as a sole proprietor or an independent contractor”, are required to pay self employment taxes.<a href="http://www.advisorfyi.com/wp-admin/post.php?action=edit&amp;post=94#_ftn4">[4]</a> The rate for this tax is 15.4% which equals the Social Security and Medicare taxes paid by traditional employees and employers.  This tax is in addition to the federal income tax.  Self employed individuals are normally required to make estimated quarterly tax payments, based on estimated quarterly net taxable income.  In 2009 only the first $106,800 of “combined wages” was subject to the self employment tax, which means after this amount, self employment taxes are not levied on any additional “combined wages.” <a href="http://www.advisorfyi.com/wp-admin/post.php?action=edit&amp;post=94#_ftn5">[5]</a></p>
<p>For a detailed analysis regarding independent contractors, see Tax Facts <a href="http://www.advisorfx.com/articles/nuco-article.aspx?filename=0814-00-tf1" target="_blank">Q 814. How are business expenses reported for income tax purposes</a>?</p>
<p><em>We invite your questions and comments by posting them below, or by calling the <a href="http://www.advisorfyi.com/about/" target="_blank">Panel of Experts</a>.</em></p>
<hr size="1" /><a href="http://www.advisorfyi.com/wp-admin/post.php?action=edit&amp;post=94#_ftnref1">[1]</a> 26 U.S.C.A. 61(a), 26 U.S.C.A. 61(a)(1)</p>
<p><a href="http://www.advisorfyi.com/wp-admin/post.php?action=edit&amp;post=94#_ftnref2">[2]</a> 26 U.S.C.A. 162(a)</p>
<p><a href="http://www.advisorfyi.com/wp-admin/post.php?action=edit&amp;post=94#_ftnref3">[3]</a> 2009 Internal Revenue Service Form 1120S</p>
<p><a href="http://www.advisorfyi.com/wp-admin/post.php?action=edit&amp;post=94#_ftnref4">[4]</a> “Self Employment Tax Article”.  Internal Revenue Service.  May 20, 2010.<em> </em><a href="http://www.irs.gov/businesses/small/article/0,,id=98846,00.html">http://www.irs.gov/businesses/small/article/0,,id=98846,00.html</a> Last Accessed 8/18/2010.</p>
<p><a href="http://www.advisorfyi.com/wp-admin/post.php?action=edit&amp;post=94#_ftnref5">[5]</a> Id.</p>
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		<title>Tax Tips for Job Hunters and Career Changers</title>
		<link>http://www.advisorfyi.com/2012/03/tax-tips-for-job-hunters-and-career-changers/</link>
		<comments>http://www.advisorfyi.com/2012/03/tax-tips-for-job-hunters-and-career-changers/#comments</comments>
		<pubDate>Sun, 11 Mar 2012 19:40:50 +0000</pubDate>
		<dc:creator>George Mentz JD, MBA, CWM, MFP - International Lawyer and Award Winning Author</dc:creator>
				<category><![CDATA[Uncategorized]]></category>
		<category><![CDATA[careers]]></category>
		<category><![CDATA[expenses]]></category>
		<category><![CDATA[Job hunting]]></category>
		<category><![CDATA[loopholes]]></category>
		<category><![CDATA[tax deductions]]></category>
		<category><![CDATA[tax tips]]></category>
		<category><![CDATA[Unemployment]]></category>

		<guid isPermaLink="false">http://www.advisorfyi.com/?p=2793</guid>
		<description><![CDATA[If you have been out of work or looking for a job, here are some tips from the IRS that you may find useful.   These tips may also help you get more money back or even bigger deductions for looking for work.]]></description>
			<content:encoded><![CDATA[<p><strong><strong>Seven Tax Tips for Job Seekers  – Edited by G. Mentz, JD, MBA, CWM® </strong></p>
<p>If you have been out of work or looking for a job, here are some tips from the IRS that you may find useful.   These tips may also help you get more money back or even bigger deductions for looking for work.</p>
<p>Many taxpayers spend time during the recent months updating their résumé and attending career fairs. </p>
<p><strong>Here are seven things the IRS wants you to know about deducting costs related to your job search:</strong></p>
<p>1. To qualify for a deduction, the expenses must be spent on a job search in your current occupation. You may not deduct expenses you incur while looking for a job in a new occupation.  This same rule tends to apply to education that you seek that will allow you to engage in a new occupation.</p>
<p>2. You can deduct employment and outplacement agency fees you pay while looking for a job in your present occupation. If your employer pays you back in a later year for employment agency fees, you must include the amount you receive in your gross income, up to the amount of your tax benefit in the earlier year.</p>
<p>3. You can deduct amounts you spend for preparing and mailing copies of your résumé to prospective employers as long as you are looking for a new job in your present occupation.</p>
<p>4. If you travel to an area to look for a new job in your present occupation, you may be able to deduct travel expenses to and from the area. You can only deduct the travel expenses if the trip is primarily to look for a new job. The amount of time you spend on personal activity compared to the amount of time you spend looking for work is important in determining whether the trip is primarily personal or is primarily to look for a new job.</p>
<p>5. You cannot deduct job search expenses if there was a substantial break between the end of your last job and the time you begin looking for a new one.</p>
<p>6. You cannot deduct job search expenses if you are looking for a job for the first time.</p>
<p>7. The amount of job search expenses that you can claim on your tax return is limited. You can claim the amount that is more than 2 percent of your adjusted gross income.  You figure your deduction on Schedule A.</p>
<p>For more information about job search expenses, see IRS Publication 529, Miscellaneous Deductions. This publication is available on www.irs.gov or by calling 800-TAX-FORM (800-829-3676).</p>
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		<title>Ten Tax Benefits for Parents</title>
		<link>http://www.advisorfyi.com/2012/03/ten-tax-benefits-for-parents/</link>
		<comments>http://www.advisorfyi.com/2012/03/ten-tax-benefits-for-parents/#comments</comments>
		<pubDate>Wed, 07 Mar 2012 00:51:32 +0000</pubDate>
		<dc:creator>George Mentz JD, MBA, CWM, MFP - International Lawyer and Award Winning Author</dc:creator>
				<category><![CDATA[Uncategorized]]></category>

		<guid isPermaLink="false">http://www.advisorfyi.com/?p=2767</guid>
		<description><![CDATA[Your kids can be helpful at tax time. That doesn't mean they'll sort your tax receipts or refill your coffee, but those charming children may help you qualify for some valuable tax benefits. Here are 10 things the IRS wants parents to consider when filing their taxes this year.]]></description>
			<content:encoded><![CDATA[<p><strong>IRS Reminds Parents of Ten Tax Benefits</strong> Edited by George Mentz, JD, MBA, CWM</p>
<p>Your kids can be helpful at tax time. That doesn&#8217;t mean they&#8217;ll sort your tax receipts or refill your coffee, but those charming children may help you qualify for some valuable tax benefits. Here are 10 things the IRS wants parents to consider when filing their taxes this year.</p>
<p>1.	Dependents In most cases, a child can be claimed as a dependent in the year they were born. For more information see IRS Publication 501, Exemptions, Standard Deduction, and Filing Information.<br />
2.	Child Tax Credit You may be able to take this credit for each of your children under age 17. If you do not benefit from the full amount of the Child Tax Credit, you may be eligible for the Additional Child Tax Credit. For more information see IRS Publication 972, Child Tax Credit.<br />
3.	Child and Dependent Care Credit You may be able to claim this credit if you pay someone to care for your child or children under age 13 so that you can work or look for work. See IRS Publication 503, Child and Dependent Care Expenses.<br />
4.	Earned Income Tax Credit The EITC is a tax benefit for certain people who work and have earned income from wages, self-employment or farming. EITC reduces the amount of tax you owe and may also give you a refund. IRS Publication 596, Earned Income Credit, has more details.<br />
5.	Adoption Credit You may be able to take a tax credit for qualifying expenses paid to adopt an eligible child. If you claim the adoption credit, you must file a paper tax return with required adoption-related documents. For details, see the instructions for IRS Form 8839, Qualified Adoption Expenses.<br />
6.	Children with earned income If your child has income earned from working, they may be required to file a tax return. For more information, see IRS Publication 501.<br />
7.	Children with investment income Under certain circumstances a child’s investment income may be taxed at their parent’s tax rate. For more information, see IRS Publication 929, Tax Rules for Children and Dependents.<br />
8.	Higher education credits Education tax credits can help offset the costs of higher education. The American Opportunity and the Lifetime Learning Credits are education credits that can reduce your federal income tax dollar-for-dollar. See IRS Publication 970, Tax Benefits for Education, for details.<br />
9.	Student loan interest You may be able to deduct interest paid on a qualified student loan, even if you do not itemize your deductions. For more information, see IRS Publication 970.<br />
10.	Self-employed health insurance deduction If you were self-employed and paid for health insurance, you may be able to deduct any premiums you paid for coverage for any child of yours who was under age 27 at the end of the year, even if the child was not your dependent. For more information, see the IRS website.</p>
<p>Also, anytime is a good time to start a college education fund whether IRA, 529 or State Plan.  Further, dont forget that you can contribute to some of your retirement funds before April 15.<br />
See www.irs.gov</p>
<p>No Tax Advice Implied Herein.  Please consult your local licensed CPA or Attorney before making any important decision.</p>
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		<title>Offshore Planning’s Impact on Calculation of U.S. Income Tax Liability</title>
		<link>http://www.advisorfyi.com/2012/03/offshore-planning%e2%80%99s-impact-on-calculation-of-u-s-income-tax-liability/</link>
		<comments>http://www.advisorfyi.com/2012/03/offshore-planning%e2%80%99s-impact-on-calculation-of-u-s-income-tax-liability/#comments</comments>
		<pubDate>Thu, 01 Mar 2012 12:00:38 +0000</pubDate>
		<dc:creator>Prof. William Byrnes</dc:creator>
				<category><![CDATA[Uncategorized]]></category>
		<category><![CDATA[Business]]></category>
		<category><![CDATA[Congress]]></category>
		<category><![CDATA[Corporation]]></category>
		<category><![CDATA[income tax]]></category>
		<category><![CDATA[Investment]]></category>
		<category><![CDATA[Tax]]></category>
		<category><![CDATA[Taxation]]></category>
		<category><![CDATA[United States]]></category>

		<guid isPermaLink="false">http://www.advisorfyi.com/?p=327</guid>
		<description><![CDATA[Discusses some of the impacts offshore planning can have on U.S. taxpayers in regards to estate planning.  Provides wealth managers a review of international taxation as it relates to clients generally.  ]]></description>
			<content:encoded><![CDATA[<p><em>Why is this Topic Important to Wealth Managers? </em> <em>Discusses how international planning can impact clients’ tax position domestically.  Provides discussion on a number of common international tax concepts as they relate to U.S. taxpayers. </em><strong> </strong></p>
<p>In a previous blog, it has been briefly discussed that there may be a number of reasons a client may consider offshore planning, generally.  Today we will focus on one major component of offshore considerations, the impact of world-wide income on U.S. taxpayers. It is generally accepted that U.S. taxpayers are expected to pay income taxes on income earned from sources worldwide.<a href="file:///C:/Documents%20and%20Settings/user/Local%20Settings/Temporary%20Internet%20Files/Content.IE5/N8LNP2U5/09_29_10_AdvisorFYI_blog%2520%5bOffshore%2520Planning%E2%80%99s%2520Impact%2520on%2520Calculation%2520of%2520U.S.%2520Income%2520Tax%2520Liability%2520%5d-33%5b1%5d.doc#_ftn1">[1]</a> This concept is commonly referred to as “outbound” taxation. <a href="file:///C:/Documents%20and%20Settings/user/Local%20Settings/Temporary%20Internet%20Files/Content.IE5/N8LNP2U5/09_29_10_AdvisorFYI_blog%2520%5bOffshore%2520Planning%E2%80%99s%2520Impact%2520on%2520Calculation%2520of%2520U.S.%2520Income%2520Tax%2520Liability%2520%5d-33%5b1%5d.doc#_ftn2">[2]</a></p>
<p>It is the case that many sovereign nations will also have taxes on personal and/or corporate income that an individual or corporation could become subject to, creating in effect “double taxation.”  And some <a class="zem_slink" title="Foreign corporation" rel="wikipedia" href="http://en.wikipedia.org/wiki/Foreign_corporation">foreign</a> nations choose to have very low or no tax rate on certain types of income, or on corporations in general, thus allowing foreign income to potentially escape foreign taxation (and current U.S. taxation in the year that it is earned).</p>
<p>What are some rules that that Congress has attempted to avoid double taxation or subject foreign income to U.S. taxation?</p>
<p><strong><em>Foreign Tax Credit</em></strong></p>
<p><em> </em></p>
<p>Under the foreign tax credit, the “United States allows its taxpayers to reduce their U.S. tax liability by some or all of the foreign income taxes paid on income earned outside the United States.” <a href="file:///C:/Documents%20and%20Settings/user/Local%20Settings/Temporary%20Internet%20Files/Content.IE5/N8LNP2U5/09_29_10_AdvisorFYI_blog%2520%5bOffshore%2520Planning%E2%80%99s%2520Impact%2520on%2520Calculation%2520of%2520U.S.%2520Income%2520Tax%2520Liability%2520%5d-33%5b1%5d.doc#_ftn3">[3]</a> The credit, created by Congress, reduces U.S. income by “foreign income taxes paid or accrued.”  “The credit is a dollar-for-dollar reduction of U.S. income tax liability.”  <a href="file:///C:/Documents%20and%20Settings/user/Local%20Settings/Temporary%20Internet%20Files/Content.IE5/N8LNP2U5/09_29_10_AdvisorFYI_blog%2520%5bOffshore%2520Planning%E2%80%99s%2520Impact%2520on%2520Calculation%2520of%2520U.S.%2520Income%2520Tax%2520Liability%2520%5d-33%5b1%5d.doc#_ftn4">[4]</a><br />
<strong><em> </em></strong></p>
<p><strong><em>Controlled Foreign Corporations</em></strong></p>
<p>As a general rule, “the income of a foreign corporation is included on the U.S. shareholder&#8217;s U.S. income tax return only when <a class="zem_slink" title="Dividend" rel="wikipedia" href="http://en.wikipedia.org/wiki/Dividend">dividend</a> income is received.” <a href="file:///C:/Documents%20and%20Settings/user/Local%20Settings/Temporary%20Internet%20Files/Content.IE5/N8LNP2U5/09_29_10_AdvisorFYI_blog%2520%5bOffshore%2520Planning%E2%80%99s%2520Impact%2520on%2520Calculation%2520of%2520U.S.%2520Income%2520Tax%2520Liability%2520%5d-33%5b1%5d.doc#_ftn5">[5]</a> Yet for certain situations when U.S. taxpayers have a shareholding in a foreign corporation, Congress has established special rules that “deem” a dividend to have been paid by the foreign corporation, regardless of whether it is actually paid or not.  These special rules are known as “anti-deferral” rules – rules that mitigate the tax advantages of taxpayers deferring U.S. tax until foreign income has been received.</p>
<p>In general the rules that most impact U.S. taxpayers with a shareholding in a foreign company are known as “<a class="zem_slink" title="Controlled Foreign Corporation" rel="wikipedia" href="http://en.wikipedia.org/wiki/Controlled_Foreign_Corporation">controlled foreign corporation</a>” rules (aka CFC rules).  A CFC exist when “any foreign corporation in which more than 50 percent of the total combined voting power of all classes of stock entitled to vote or the total value of the stock of the corporation is owned by U.S. shareholders on any day during the taxable year of the foreign corporation.” <a href="file:///C:/Documents%20and%20Settings/user/Local%20Settings/Temporary%20Internet%20Files/Content.IE5/N8LNP2U5/09_29_10_AdvisorFYI_blog%2520%5bOffshore%2520Planning%E2%80%99s%2520Impact%2520on%2520Calculation%2520of%2520U.S.%2520Income%2520Tax%2520Liability%2520%5d-33%5b1%5d.doc#_ftn6">[6]</a></p>
<p>Not all income earned by a CFC will be deemed as a dividend to its U.S. taxpayers.  Congress does not want to stop U.S. taxpayers from investing or doing business overseas.  However, Congress is concerned that it is common that U.S. taxpayers will “shift the income-generating activity to a foreign entity where the income earned will not be subject to U.S. tax until repatriated.” <a href="file:///C:/Documents%20and%20Settings/user/Local%20Settings/Temporary%20Internet%20Files/Content.IE5/N8LNP2U5/09_29_10_AdvisorFYI_blog%2520%5bOffshore%2520Planning%E2%80%99s%2520Impact%2520on%2520Calculation%2520of%2520U.S.%2520Income%2520Tax%2520Liability%2520%5d-33%5b1%5d.doc#_ftn7">[7]</a> Congress considers that such business activities or investment activities could have or should have occurred in the United States, or at least should have been taxed in the United States regardless of where they occurred.</p>
<p>Thus, Congress has established complex rules to determine which types of income it will allow to be earned overseas without the U.S. taxpayers incurring current U.S. taxation on a deemed dividend, and correspondingly which types of income for which Congress will disallow deferral.  Income that Congress disallows deferral for is known as ‘tainted’ income.  It is this “tainted” income that is included in the gross income of its U.S. shareholders without regard to its actual distribution.</p>
<p>Income that is subject to current taxation from a CFC, “can be characterized as income that is easily shifted or has little or no economic connection with the CFC&#8217;s country of incorporation” <a href="file:///C:/Documents%20and%20Settings/user/Local%20Settings/Temporary%20Internet%20Files/Content.IE5/N8LNP2U5/09_29_10_AdvisorFYI_blog%2520%5bOffshore%2520Planning%E2%80%99s%2520Impact%2520on%2520Calculation%2520of%2520U.S.%2520Income%2520Tax%2520Liability%2520%5d-33%5b1%5d.doc#_ftn8">[8]</a> and may include, “foreign personal holding company income, foreign based company sales [and service] income, …as well as certain insurance income, …and certain other narrowly defined categories of income [including passive income, ‘such as interest dividends rents and royalties’<a href="file:///C:/Documents%20and%20Settings/user/Local%20Settings/Temporary%20Internet%20Files/Content.IE5/N8LNP2U5/09_29_10_AdvisorFYI_blog%2520%5bOffshore%2520Planning%E2%80%99s%2520Impact%2520on%2520Calculation%2520of%2520U.S.%2520Income%2520Tax%2520Liability%2520%5d-33%5b1%5d.doc#_ftn9">[9]</a>].” <a href="file:///C:/Documents%20and%20Settings/user/Local%20Settings/Temporary%20Internet%20Files/Content.IE5/N8LNP2U5/09_29_10_AdvisorFYI_blog%2520%5bOffshore%2520Planning%E2%80%99s%2520Impact%2520on%2520Calculation%2520of%2520U.S.%2520Income%2520Tax%2520Liability%2520%5d-33%5b1%5d.doc#_ftn10">[10]</a> Well, that’s a mouthful of legal terms that we will need to discuss in future blogticles.</p>
<hr size="1" /><a href="file:///C:/Documents%20and%20Settings/user/Local%20Settings/Temporary%20Internet%20Files/Content.IE5/N8LNP2U5/09_29_10_AdvisorFYI_blog%2520%5bOffshore%2520Planning%E2%80%99s%2520Impact%2520on%2520Calculation%2520of%2520U.S.%2520Income%2520Tax%2520Liability%2520%5d-33%5b1%5d.doc#_ftnref1">[1]</a> 26 U.S.C § 61; See also, Taxation of Business Entities.  James E. Smith, William H. Raabe, David M. Maloney.  Chapter 13.  2007 Annual Edition, citing 26 U.S.C § 61, “Gross income for a U.S. person includes ‘all income from whatever source derived’.  ”Source“ in this context means not only type of income (e.g., wages or interest) but geographic source as well (e.g., the United States or Belgium). Westlaw.</p>
<p><a href="file:///C:/Documents%20and%20Settings/user/Local%20Settings/Temporary%20Internet%20Files/Content.IE5/N8LNP2U5/09_29_10_AdvisorFYI_blog%2520%5bOffshore%2520Planning%E2%80%99s%2520Impact%2520on%2520Calculation%2520of%2520U.S.%2520Income%2520Tax%2520Liability%2520%5d-33%5b1%5d.doc#_ftnref2">[2]</a> Corporations, Partnerships, Estates &amp; Trusts.  Chapter 9.  , 2007 Annual Edition.  Westlaw.</p>
<p><a href="file:///C:/Documents%20and%20Settings/user/Local%20Settings/Temporary%20Internet%20Files/Content.IE5/N8LNP2U5/09_29_10_AdvisorFYI_blog%2520%5bOffshore%2520Planning%E2%80%99s%2520Impact%2520on%2520Calculation%2520of%2520U.S.%2520Income%2520Tax%2520Liability%2520%5d-33%5b1%5d.doc#_ftnref3">[3]</a> Taxation of Business Entities. Ch 13</p>
<p><a href="file:///C:/Documents%20and%20Settings/user/Local%20Settings/Temporary%20Internet%20Files/Content.IE5/N8LNP2U5/09_29_10_AdvisorFYI_blog%2520%5bOffshore%2520Planning%E2%80%99s%2520Impact%2520on%2520Calculation%2520of%2520U.S.%2520Income%2520Tax%2520Liability%2520%5d-33%5b1%5d.doc#_ftnref4">[4]</a> Id.</p>
<p><a href="file:///C:/Documents%20and%20Settings/user/Local%20Settings/Temporary%20Internet%20Files/Content.IE5/N8LNP2U5/09_29_10_AdvisorFYI_blog%2520%5bOffshore%2520Planning%E2%80%99s%2520Impact%2520on%2520Calculation%2520of%2520U.S.%2520Income%2520Tax%2520Liability%2520%5d-33%5b1%5d.doc#_ftnref5">[5]</a> Id. citing, Subpart F, <a href="http://www.law.cornell.edu/uscode/26/usc_sup_01_26_10_A_20_1_30_N_40_III_50_F.html">§§ 951-964 of Title 26 of the United States Code</a>.</p>
<p><a href="file:///C:/Documents%20and%20Settings/user/Local%20Settings/Temporary%20Internet%20Files/Content.IE5/N8LNP2U5/09_29_10_AdvisorFYI_blog%2520%5bOffshore%2520Planning%E2%80%99s%2520Impact%2520on%2520Calculation%2520of%2520U.S.%2520Income%2520Tax%2520Liability%2520%5d-33%5b1%5d.doc#_ftnref6">[6]</a> Taxation of Business Entities.</p>
<p><a href="file:///C:/Documents%20and%20Settings/user/Local%20Settings/Temporary%20Internet%20Files/Content.IE5/N8LNP2U5/09_29_10_AdvisorFYI_blog%2520%5bOffshore%2520Planning%E2%80%99s%2520Impact%2520on%2520Calculation%2520of%2520U.S.%2520Income%2520Tax%2520Liability%2520%5d-33%5b1%5d.doc#_ftnref7">[7]</a> Id.</p>
<p><a href="file:///C:/Documents%20and%20Settings/user/Local%20Settings/Temporary%20Internet%20Files/Content.IE5/N8LNP2U5/09_29_10_AdvisorFYI_blog%2520%5bOffshore%2520Planning%E2%80%99s%2520Impact%2520on%2520Calculation%2520of%2520U.S.%2520Income%2520Tax%2520Liability%2520%5d-33%5b1%5d.doc#_ftnref8">[8]</a> Id.</p>
<p><a href="file:///C:/Documents%20and%20Settings/user/Local%20Settings/Temporary%20Internet%20Files/Content.IE5/N8LNP2U5/09_29_10_AdvisorFYI_blog%2520%5bOffshore%2520Planning%E2%80%99s%2520Impact%2520on%2520Calculation%2520of%2520U.S.%2520Income%2520Tax%2520Liability%2520%5d-33%5b1%5d.doc#_ftnref9">[9]</a> Id.</p>
<p><a href="file:///C:/Documents%20and%20Settings/user/Local%20Settings/Temporary%20Internet%20Files/Content.IE5/N8LNP2U5/09_29_10_AdvisorFYI_blog%2520%5bOffshore%2520Planning%E2%80%99s%2520Impact%2520on%2520Calculation%2520of%2520U.S.%2520Income%2520Tax%2520Liability%2520%5d-33%5b1%5d.doc#_ftnref10">[10]</a> 3 Legal Compliance Checkups § 20:35 (2009).  Westlaw.</p>
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