Analysis of and Planning for the Final Net Investment Income Tax Regulations

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The Medicare tax on net investment income is now fully effective from January 2013. The Treasury and IRS published final regulations in relation to the Medicare tax on December 2, 2013. The final regulations clarify many of the open issues from the 2012 proposed regulations. Planning opportunities and reporting issues need to be considered.

This Webinar will address the content of the final regulations and application of the Medicare tax to individuals and trusts. Particular emphasis will be placed on changes in the final regulations and on planning for trade or business income and gains in coordination with the material participation test under the passive loss rules.

In 90 minutes the speakers will cover:
•The statue and general content of the Final Regulations
•Application of the Medicare tax to individuals, trusts and estates 
•Determination of Net Investment Income 
•Allocations through and disposition of interests in pass-through entities 
•Application of the Medicare tax to CFC and PFIC income 
•Planning for real estate interests 
•Planning for trusts and material participation

Educational Objectives:
•Classify net investment income
•Determine net investment income tax
•Determine which taxpayers are subject to the net investment income tax
•Apply material participation rules for real estate professionals
•Differentiate between the 2012 proposed regulations and final regulation



James Brockway is co-chairman of the worldwide Wealth Planning practice group at the firm. His practice is global in scope with particular emphasis on offshore trust planning, planning for non-U.S. individuals and foreign assets, family investment and business planning, family offices and inbound and outbound business and income and transfer tax planning.


He also advises on corporate and partnership tax planning for closely held businesses, investment entities and funds management entities as well as on mergers and acquisitions and insurance and derivatives investment tax planning.


Jim has lectured before numerous professional groups on partnership, estate tax, life insurance and foreign investment planning issues and has written articles for professional journals and newsletters on various tax topics.  He lectured for BNA on the Section 1411 Medicare tax and the proposed Treasury Regulations in January 2012.



Marc Finer is Special Counsel in the firm’s Funds, Investments, Tax and Trusts practice in New Haven, Connecticut, where his practice focuses on federal and state and local tax planning for individuals and privately held enterprises. He also advises clients with regard to real estate tax planning, offshore trust planning, structures involving the use of life insurance and financial instruments and a variety of other transactions, including business and asset purchases and sales, joint ventures and Section 1031 like-kind exchanges.