With potential reductions in the gift, estate, and generation-skipping transfer tax exemptions looming, many practitioners are rightfully focused on planning with these exemptions. However, as part of this planning, it’s also important to not lose focus on income tax attributes.

These days, many of our clients are holding debt obligations they can’t collect. The IRC may provide some relief, in the form of a tax deduction or loss, for creditors holding a worthless (or in some cases even a partially worthless) bona fide debt, provided that conditions set forth within IRC section 166 and the related Treasury Regulations are satisfied.

Interest rates are at historic lows. This is good news for certain planning techniques and bad news for others.   

The global outbreak of COVID-19 has significantly impacted individuals and their ability to travel. Many are under state quarantine orders, “sheltering in place,” or simply afraid or uncomfortable to leave their home. Other individuals have left their home in one state for the prospect of a safer, more socially distant location in another state or country. 

At the foot of the Statue of Liberty is an inscribed plaque with a poem about America being the land that welcomes the refugee. Film footage from the turn of the 20th century depicts ships overloaded with immigrants passing the statue and dreaming of a better tomorrow in the United States.

As we continue to adjust to the impact of the COVID-19 crisis and rethink how business gets done, it’s important to realize how far we’ve come in this short amount time. Managing through this pandemic has allowed us to adapt and stretch our creativity to safeguard business continuity and exhibit resiliency. For many of us, technology was at the forefront of our ability to continue moving forward—or, at the very least, not move backward.

In an effort to extend additional relief to opportunity zones in light of the COVID-19 pandemic, the IRS issued Notice 2020-39 on Jun. 4, 2020. It provides very significant relief for qualified opportunity funds (QOF) and their investors.