December 1996 Hot Topics

December, 1996 -- Year-End Tax Planning Opportunities and Traps

It's the holiday season - time for revelry, family clashes and, oh yes: year-end tax planning. During this holiday season, do yourself a financial favor by reviewing your tax situation with a professional. Who knows? There might be enough savings to partially off-set your holiday spending. At least skim through the following list of tax-planning opportunities and traps, before uncorking the Champagne in 1997.

TAX BENEFITS TO CONSIDER

States Cannot Tax the Pensions of Their Former Residents

In 1996, Congress passed legislation, principally aimed at California and other tax aggressive states, to prevent them from taxing the pension and retirement benefits earned by former residents. You can now work and earn retirement benefits in one state, then retire in a low tax state, without paying taxes on your retirement benefits. Therefore, do not file a tax return or pay any taxes with respect to your retirement benefits, except to the state in which you now reside.

Collecting on Debts Owed to You

Remember that loan you made to your deadbeat Uncle Harry years ago? You are permitted to take a bad debt deduction on your tax returns for that loan, provided the debt becomes worthless. To establish worthless, you must take affirmative steps to collect the debt during the year it becomes worthless. In Uncle Harry's case, write him a letter (return receipt requested), demanding full payment. It is not necessary to sue the person, if such an action would be fruitless.

The bad debt deduction is usually a capital loss. However, if you own stock in a small corporation that becomes worthless (the company goes out of business or is insolvent), you may be entitled to an ordinary loss under the Section 1244 stock rules. Keep this in mind if you make a stock investment in a family corporation. Check with the corporation to determine whether your worthless stock is Section 1244 stock.


INVESTMENT DECISIONS

Recognizing Capital Losses and Repurchasing the Same Stock

If you have capital gains, consider selling those stocks which will generate a capital loss, prior to the end of 1996. Capital gains are netted against capital losses. Capital losses that exceed capital gains may offset ordinary income up to $3,000 per year and can be carried forward indefinitely until used in full.

Wash Transactions

Suppose you own a stock that has lost value, but want to keep it. Can you sell it, recognize the loss, then repurchase it? Yes, if you wait at least 31 days before repurchasing it. This is called a "wash transaction" and the rules state that you cannot acquire "substantially identical securities within a 61 day period which begins 30 days before the sale and ends 30 days after it.

Suppose two years ago you purchased 1,000 shares at $90/share which is now worth $50/share. You might: (a) sell the shares and recognize a $40/share capital loss, then repurchase the stock 31 days later; (b) buy 1,000 shares of the stock at $50/share, then sell the original lot 31 days later; or (c) sell the stock and immediately buy stock in a similar company, hold the new stock for 31 days then sell it, and then repurchase shares in the original company. Each strategy has its own set of risks, but all circumvent the wash sale rules and permit you to deduct the loss on the original stock.

Shift Income to Your Children

There is a tax break that almost every family can successfully utilize: A child's unearned income (interest, dividends, rents or royalties) to $650 is not taxed, and income from $650 to $1,300 is taxed at a 15% tax bracket. Therefore, a gift transfer to a child of $10,000 which earns 6.5% annually will not be taxed. A transfer of $20,000 earning 6.5% annually ($1,300 in income) will produce just a $97.65 tax (15% of $650) to the child. If the same income were taxed to a parent in the 31% tax bracket, the tax would be $403.

Parents who own their own businesses are permitted to hire a child and the income (which is considered earned income) is taxed to the child. Also, any other earned income by a child, such as a paper route, will be taxed to the child.

If a child is under age 14, then unearned income over $1,300 is taxed at the parent's tax bracket; children over age 14 are taxed at their bracket which is usually 15%. Carefully drafted college trusts and other types of financial arrangements for children over age 14 can take advantage of the child's lower tax bracket as well as protect those funds from the parent's potential creditors.

A variation on the college trust arrangement is now possible under recently enacted tax legislation which allows states to create tuition guaranty programs. A trust is formed with the child as the beneficiary. The trust's earnings are tax-free until withdrawn for tuition and the income generated by the trust is taxed to the child (at the lower tax brackets).

Itemized Miscellaneous Deductions

Teachers who spend their own money on classroom supplies may deduct a portion of those expenses, if they itemize their deductions, rather than using the standard deduction. Itemized miscellaneous deductions, which includes unreimbursed business expenses, union or professional dues, tax preparation, income or investment related expenses and education, are deductible, provided they exceed 2% of a taxpayer's adjusted gross income ("AGI"). If a teacher's AGI is $40,000, then expenses over $800 are deductible. For example, if a teacher earning $40,000 a year pays $500 in union dues, $500 for continuing education and $1,000 in classroom supplies, the itemized miscellaneous deduction will be $1,200 ($2,000 less the $800 floor). In this case, it is beneficial to bunch expenses in one year, if possible (purchase supplies needed for the remaining school year in 1996). These rules apply to others who incur business related expenses in their occupations.


TECHNIQUES INVOLVING THE ACCELERATION OF INCOME INTO 1996

If your income will be relatively lower for 1996 (loss of a job, one parent working) or if you expect an increase in income for 1997, there are several ways to accelerate income into 1996.

Change in Filing Status

If you are involved in a divorce, you may want to accelerate income into 1996 while you are permitted to file a joint return.

Those Subject to the Alternative Minimum Tax ("AMT")

If you are subject to the AMT, you may want to accelerate income into 1996 since the additional income may not have an effect on your tax bracket under the AMT.

Expiration of Net Operating Losses or Too Many Deductions

If you have net operating losses which are going to expire, or otherwise have excess deductions, then accelerating income into 1996 could be a shrewd move.

Capital Gains

Sell stocks at a capital gain; or sell appreciated stocks held less than one year for a short-term capital gain which will be taxed at ordinary income tax rates.

Lawsuits or Collections

Settle a lawsuit this year or arrange for the collection of money this year. Offer a discount if feasible. In reality, your creditors might want to take the deduction this year anyway so this could be a win-win situation.

Installment Notes

You can accelerate the income from an installment note by having the payor pay it off this year, by selling the note to a third party, or by borrowing a sum of money and using the note as collateral for the loan. An extra interest payment made in late December will shift 13 months of interest income into 1996 and 11 months of interest income into 1997.

IRA's and Retirement Plans

If you are eligible to withdraw funds from a retirement account, check with your plan provider as to whether you can withdraw additional income under the plan this year. Make sure not to exceed the maximum yearly limit.

Employee Stock Options

If you have an incentive stock option plan, check to determine whether you can exercise your stock option and sell the stock this year.

Section 83 Stock

Restricted stock is stock provided in connection with your employment that is subject to a substantial risk of forfeiture. This stock is not considered yours for tax purposes until the restrictions lapse. You can, however, make a special election (Section 83(b) election) to treat the stock as yours currently and pay the tax on the stock's value at the time of election. This will accelerate the stock's value as income to you in 1996. The downside is if the stock does not become vested, you will have paid for something with no value. On the upside, if the stock increases greatly in value, you'll be entitled to capital gains treatment on the appreciation.

Example: If you have 100 shares of restricted stock with a fair market value of $2/share and you make a Section 83 (b) election, you'll be taxed on $200 of income. If the stock then appreciates to $100/sh and you sell it, you'll have capital gains on $98/sh of gain. If you did not make a Section 83(b) election, then the entire $100/sh would be taxed as ordinary income to you.

Collect Receivables and Bonuses

If you own your business, attempt to collect your outstanding accounts receivable in 1996. If you are an employee, request that any bonuses be paid to you on or before December 31st.

Acceleration of Distributions by Corporations, Partnerships or Trusts.

To the extent possible, have dividends from a C corporation paid to you prior to the end of the year. Purchasing a mutual fund which will pay a year-end dividend will also accelerate income.

If you own S corporation stock or a partnership interest, the corporation or partnership will have to generate income by either collecting receivables or postponing deductions this year, since you'll be taxed on your allocable share of income and gains from these entities. If you are an active shareholder or partner, take a larger salary this year or (if your entity files tax returns on a calendar year basis) postpone deductions for the entity, such as interest payments, rental payments or payments to suppliers until next year.

Trust distributions should be made timely (usually within 65 days from the end of the taxable year). Discuss with your trustee the possibility of receiving a distribution to you that will count as income in 1996.


ACCELERATING INCOME BY DEFERRING DEDUCTIONS TO NEXT YEAR.

If you itemized your deductions, delay mortgage payments, state tax payment and other deductible expenses until 1997. Paying expenses on January 1, 1997 which are part of your itemized deductions, such as medical expenses (to the extent they exceed 7.5% of AGI), property taxes, mortgage interest deductions on a first or second home, charitable contributions and itemized miscellaneous deductions (to the extent they exceed 2% of AGI), will increase your taxable income by decreasing your deductions.

Note: The delay will not cause your creditor any financial problems since there is no practical difference between a check dated December 31st and one dated January 1st, since New Year's day is an official holiday anyway.


DEFERRING INCOME TO 1997

If you expect to be in a lower tax bracket next year, there are several ways to defer income to 1997 and to accelerate deductions into 1996.

Defer Sales of Property and Year-End Bonuses and Distributions to 1997

Sell appreciated stock or other types of investment property in 1997. Delay taking more than the minimum from retirement accounts in 1996. Request that year-end bonuses be paid in January, 1997. Settle lawsuits in 1997 and ask creditors who owe you money to delay paying the December installment until January 1st .


TECHNIQUES TO ACCELERATE DEDUCTIONS

Payments by check and by credit card made in 1996 count as deductions in 1996, even though the credit card is paid off in 1997. If you have several large amounts outstanding, obtain a home-equity line of credit (or use the one you already have in place) to pay the expenses in 1996. Prepay your January mortgage or rental expenses in December. Pay any other outstanding liabilities in 1996. Pay your employees their bonuses in 1996.

Purchase Equipment in 1996

Purchase computer equipment that you will use in business in 1996. The maximum amount of equipment that is eligible for a full deduction is $17,500 per year. Buy that color printer you've been eyeing, or that laptop computer. If you borrow the money for these purchases, you'll receive a current deduction even though the pay back will occur in 1997 and thereafter.

Gifts of Appreciated Property to Charity

Make a gift of appreciated property to charity. You'll obtain a current deduction for the fair market value of the property without incurring out-of-pocket expenses. There are strict substantiation rules for gifts of property over $250 in value.

Write-off Worthless Debts this Year.

Make an earnest attempt to collect outstanding debts this year and then declare them as bad debts. You must be able to show the debt became worthless in 1996. Remember, cash basis companies (this includes most small service businesses) cannot deduct an uncollected receivable as a bad debt, rather, it must involve money owed to you or an investment made by you that has become worthless.

Maximize Contributions to Retirement Plans and 401K Plans

Determine the maximize you can contribute to your retirement or 401 K plans and make the contribution. Note: The recent change allowing a $2,000 IRA deduction for a non-working spouse is effective in 1997, so this break will not help you in 1996.


TRAPS TO AVOID IN 1996

Accelerated Death Benefits

Beginning in 1997, death benefits paid to the chronically ill or terminally ill may be received prior to death on a tax-free basis. Delay receiving these benefits to 1997. If you have received death benefits in 1996, argue that these benefits were tax-free to you under the Treasury's temporary regulation permitting such treatment.

Spousal IRA

Beginning in 1997, a non-working spouse will be entitled to fund an IRA with up to $2,000 (up from the present $250). Do not fund a non-working spouse's IRA with more than $250 in 1996.

Purchase of a Mutual Fund

Delay purchasing a mutual fund late in the year since the fund might immediately issue a taxable dividend to you. Purchase the fund after the "ex-dividend" date, the date in which a dividend has been declared. Also, if you invest in a mutual fund that has a high turnover ratio of investments, you could be taxed on capital gains from those transactions, even though you have not sold any of your mutual fund shares. Also, the wash sale rules described above will apply if your distributions are automatically reinvested into fund shares and then you sell your shares at a loss within 30 days.

Delay Adopting a Child to 1997

A new $5,000 tax credit for qualified adoption expenses such as legal fees and court costs ($6,000 for the adoption of a special needs child) goes into effect in 1997.

Note: expenses for a surrogate parent are not considered qualified adoption expenses.

The credit will be phased out ratably for AGIs between $75,000 and $115,000.

Suspension of Excise Tax on Excess Distributions from Retirement Plans

The 15% excise tax on excess distributions (currently, the tax applies on distributions over $150,000 a year) under IRC Sec. 4980A has been waived for tax years 1997, 1998 and 1999. This applies only to lifetime distributions. The excise tax will apply to excess accumulations at death. Wait until next year to take an excess distribution from a retirement plan.

Sale of a Home

Both President Clinton and Senator Dole proposed a radical tax break for the sale of a principal residence. The present system of a tax-free rollover under IRC Sec. 1034) and the once-in-a-lifetime exemption of $125,000 for persons over age 55 would be replaced by a $500,000 exclusion of profits available to anyone who sells a home. The $500,000 exclusion under Clinton's plan would apply once every two years. Whether Congress will pass this legislation is unclear, but anyone contemplating the sale of a home should wait until 1997 to see whether this legislation is passed.

Deferred Tax-Free Exchanges under IRC Sec. 1031

Under the deferred exchange rules, people mistakenly believe they have 180 from the date of sale on the first leg of the transaction to complete the acquisition of the replacement property on the second leg of the transaction. The deadline is actually 180 days or the due date of the tax return (with extensions). Those selling property late in the year may run afoul of this rule if they fail to acquire the replacement property by April 15, 1997 and fail to obtain an extension on their tax return.


ESTATE AND GIFT TAX PLANNING

Maximum Your Annual Gift Tax Exclusion

You may gift up to $10,000 per year in cash or property per beneficiary without incurring a gift tax. Husband and wives may gift up to $20,000 per year per beneficiary. A gift of cash or property may be given to a properly drafted trust so that the beneficiaries will not have ownership of the asset when they reach the age of majority.

Consider giving an undivided interest in an asset, such as real property, rather than cash. The benefits are two-fold: first, you will not deplete your cash reserve by making a gift of property rather than cash and second, the gift of property might qualify for a "minority" discount, if the beneficiary ends up with less than a majority interest in the asset.

Using the Minority Discount Rules

The minority discount rules work as follows: Suppose you are married and own real estate worth $200,000. If you and your spouse gift $20,000 of the property, the beneficiary receives a 10% interest in the property. However, assuming the undivided interest is subject to a 30% minority discount, then the $20,000 interest would be worth $14,000, which is less than the $20,000 annual gift tax limit.

Thus, with a 30% minority discount, you and your spouse may in effect gift $28,500 of the property per year, and remain under the $20,000 gift tax limit ($28,500 discounted by 30% is $19,550, which is less than the $20,000 gift tax limit). Note: 30% is a typical discount percentage used, but there is no uniform standard discount and you'll need an appraisal to justify the discount percentage applied to your particular asset.

Using this technique, one can gift a much larger percentage of property than the equivalent amount of cash. Also, one can greatly leverage the annual gift tax exemption to reduce the donor's estate for estate tax purposes while shifting the future appreciation of that asset to the child.


For example, compare the difference between a gift of cash of $20,000, which earns 5% interest, and a gift of $28,500 of property valued at $200,000 (which is within the $20,000 annual gift tax limit, assuming the 30% minority discount applies). At the end of 10 years (using a simple interest calculation) the beneficiary's stake in the property would be worth $42,750, but the bank account would be worth $30,000. The interest earned would be subject to ordinary income taxes (currently a maximum federal tax rate of 39.6%), but the property's appreciation is not subject to tax until the asset is sold, and then is subject to capital gains taxes (currently a maximum federal tax rate of 28%). In addition, the property may be part of a tax-free Section 1031 exchange which would defer taxation until the property is later sold for cash.




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**NOTE: The information contained at this site is for educational purposes only and is not intended for any particular person or circumstance. A competent tax professional should always be consulted before utilizing any of the information contained at this site.**