William Byrnes on Muck Rack

William Byrnes

As seen in: LinkedIn, Law.com, The Street, CityNews Ottawa, ThinkAdvisor, TaxProf Blog, BenefitsPRO Magazine, Credit Union Times, Treasury and Risk
Covers:  estate planning and advanced estate planning, fatca, online education, tax evasion, financial crimes, retirement planning, transfer pricing, tax information exchange, insurance products, annuity products, beps, international tax, distance learning, legal education, tax, financial regulation, financial planning
Texas A&M Law, 9 Lexis treatises & 3 Tax Facts books, 1,600 articles financial media, pioneer online legal education, Phish Phell
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Fixed annuity sales rising in 2014, but why now?

Fixed annuity sales rising in 2014, but why now?

www.lifehealthpro.com — New studies show that, despite relatively stable conditions, fixed annuity sales have increased considerably in 2014 over 2013, as a perhaps unexpected number of clients flock toward these traditional guaranteed income products. While it is unsurprising that products providing guaranteed income for retirees are popular, what is surprising is that the historical motivations behind an upswing in fixed annuity sales are simply not present in today's market. Fixed annuities are undeniably trending, but as financial producers and clients alike evaluate retirement income planning goals, the headlines being made by these products has everyone asking the same question: why buy a fixed annuity today?
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A smarter strategy for recharacterizing Roths

A smarter strategy for recharacterizing Roths

www.lifehealthpro.com — The benefits of creating a stream of tax-free income during retirement is key to most successful retirement income strategies , and a Roth conversion that allows the client to "undo" the transaction if investments perform poorly is an attractive option for accomplishing this goal. However, despite the benefits that recharacterizing a Roth conversion can offer, this route can sometimes function as a double-edged sword by erasing the gains on successful investments within the account. Despite this, a carefully planned Roth conversion strategy can help clients avoid this risk: by using separate accounts, clients can maximize the value of their converted retirement funds and simultaneously take full advantage of the ability to recharacterize underperforming Roth investments.
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Using Qualified Plan Dollars to Buy Life Insurance

Using Qualified Plan Dollars to Buy Life Insurance

www.thinkadvisor.com — This copy is for your personal, non-commercial use only. To order presentation-ready copies for distribution to your colleagues, clients or customers, click the "Reprints" link at the bottom of any article. For a small business owner, using qualified plan dollars to purchase life insurance protection is a strategy that can satisfy a variety of needs. It's also a step that can make all the difference in ensuring a smooth transitioning of the business upon the owner's exit. Using pre-tax dollars to purchase an asset that provides for a tax-free benefit can make the cost of life insurance protection much more affordable, but clients need to understand the different tax treatments that apply to life insurance when it is purchased through a qualified plan.
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How qualified plan dollars multiply the value of life insurance

How qualified plan dollars multiply the value of life insurance

www.lifehealthpro.com — For a small business owner , using qualified plan dollars to purchase life insurance protection is a strategy that can satisfy a variety of needs and is one that can make all the difference in ensuring a smooth transitioning of the business upon the owner's exit. Using pre-tax dollars to purchase an asset that provides for a tax-free benefit can make the cost of life insurance protection much more affordable, but clients need to understand the different tax treatment that applies to life insurance when it is purchased through a qualified plan.
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Reversionary Annuities Gain Traction Among Insurance Carriers

Reversionary Annuities Gain Traction Among Insurance Carriers

www.thinkadvisor.com — In today's market for financial products, the array of life insurance and annuity options that are available can seem staggering at times, especially for clients whose primary goal is to provide pure life insurance protection, whether business or personal. For these clients, the costs and complications required to secure many of the bells and whistles that can accompany today's most valuable life insurance products may deter life insurance planning entirely. Fortunately, the reversionary annuity is gaining traction among carriers-as a product that combines features of both annuities and life insurance in order to provide guaranteed income to survivors-but with modifications that allow it to be stripped of the high-end price tag that often accompanies the modern financial product.
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The tax planning tip that will prove an advisor's worth in 2014

The tax planning tip that will prove an advisor's worth in 2014

www.lifehealthpro.com — As many clients learned firsthand during the 2013 tax season, the new 3.8 percent net investment income tax (NIIT), also known as the additional Medicare tax , has created new planning challenges that have not yet shown up on many advisors' radar. In year one, this was perhaps unavoidable, as advisors and clients alike adjusted to the intricate set of circumstances that can trigger the tax, but planning to minimize the additional tax hit will prove an advisor's worth in 2014. This is especially the case because the otherwise sensible retirement income-planning strategies employed by even the most tax-savvy advisors can actually create NIIT liability where none existed before.
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Private Placement Variable Annuities: The Luxury Retirement Vehicle of the Future

Private Placement Variable Annuities: The Luxury Retirement Vehicle of the Future

www.thinkadvisor.com — In most instances, the needs of the ultra-high-net-worth client simply cannot be met through the traditional retirement planning vehicles and strategies that are useful to even moderately wealthy clients. The traditional tax-preferred planning vehicles can create undesirable limits for these ultra wealthy clients, who have more cash to spare and require high-performing investment vehicles. Private placement variable annuity (PPVA) investments are fast becoming the luxury vehicles of the future, and-for the truly wealthy client-PPVA investments can provide a combination of tax benefits and investment control that drive tax and retirement income planning to the next level. What Is a Private Placement Variable Annuity Investment?
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Final longevity annuity regulations clear path for future growth

Final longevity annuity regulations clear path for future growth

www.lifehealthpro.com — Recently, the Treasury Department issued final regulations governing qualified longevity annuity contracts (QLACs) that are likely to cause sparks to fly in the annuity industry in the coming years. While many of the final QLAC provisions mirror those found in the proposed regulations that were issued more than two years ago, the final regulations have made the Treasury's commitment to expanding access to this valuable type of longevity insurance clearer than ever.
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July 1st FATCA FFI List Analysis by Country and by IGA

July 1st FATCA FFI List Analysis by Country and by IGA

profwilliambyrnes.com — free chapter download here -> http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2457671 What I find surprising thus far is that I thought (as did many large firm attorneys) many, many more registrations would have pushed themselves through the keyhole. I was thinking in the range of 100,000 to 110,000 would be registered for the July 1 FFI list. Only 10,000 additional registrations was not even in my lowest estimates. I wouldn’t call 88,000 FFI registrations a great success at this stage, considering that nearly 150 countries do not have an IGA and thus FATCA 30% withholding starts today. While the IRS suggested a 500,000 potential FFI registration figure, many industry stakeholders suggest that 800,000 – 900,000 firms fall under the expansive definition of financial institution.
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Swiss Banks Lost $383 Billion So Far Due To Tax Evasion Investigations

Swiss Banks Lost $383 Billion So Far Due To Tax Evasion Investigations

lawprofessors.typepad.com — On January 25, Kathryn Keneally, assistant attorney general of the Justice Department's Tax Division, served as the keynote speaker for the American Bar Association Section of Taxation 2014 Midyear Meeting. to provide agency updates - including on the Switzerland banks non-prosecution agreement program that expired December 31. David Voreacos of Bloomberg News reported that Kathryn Keneally, in her keynote remarks, stated that 106 Swiss banks (of approximately 300 total) filed the requisite letter of intent to join the Program for Non-Prosecution Agreements or Non-Target Letters (the " Program") by the December 31, 2013 deadline.
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FATCA remarks and intro to W-8BEN analysis

FATCA remarks and intro to W-8BEN analysis

lawprofessors.typepad.com — I think it appropriate to begin this week with a quote by Senator Russell Long (of Louisiana) who was Chairman of the Finance Committee in 1969. Senator Long, speaking of the Tax Reform Act of 1969 stated: " when the Finance Committee began public hearings on the Tax Reform Act of 1969 I referred to the bill as '368 pages of bewildering complexity.'
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States and Cities Committing Securities Fraud?

States and Cities Committing Securities Fraud?

lawprofessors.typepad.com — Monday, August 11, 2014 The Securities and Exchange Commission today announced securities fraud charges against the state of Kansas stemming from a nationwide review of bond offering documents to determine whether municipalities were properly disclosing material pension liabilities and other risks to investors. According to the SEC's cease-and-desist order instituted against Kansas, the state's offering documents failed to disclose that the state's pension system was significantly underfunded, and the unfunded pension liability created a repayment risk for investors in those bonds.
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