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George Abney

George Abney

About George Abney

George Abney is a partner on the firm’s Tax Controversy Team, whose practice focuses on civil and criminal tax controversy matters. George has significant trial and appellate experience gained from years as a federal prosecutor with the Tax Division of the U.S. Department of Justice in Washington, D.C., and as an assistant U.S. attorney in the Northern District of Florida.

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Splitting the Difference: IRS Applies Exempt Organization Excise Tax to Split-Dollar Life Insurance Policies

July 9, 2020 By George Abney, Mark Williamson, Daniel Reach and April McLeod

Our Federal Tax Group delves into proposed Treasury regulations addressing exempt organizations’ below-market loans used to pay for split-dollar life insurance premiums. Split-dollar life insurance loans became even more beneficial after the TCJA added a new excise tax on exempt organizations under Section 4960Imputed income from below-market split-dollar life insurance loans must be included in Section 4960 calculationImputed income can be avoided by charging interest at the historically low applicable federal rate Read the full advisory here. To learn more about our exempt organization [...]Read more

Filed Under: Exempt Organization, Federal Tax Advisory Tagged With: AFR, applicable federal rate, below-market loans, excise tax, Section 4960, Section 7872, split-dollar, TCJA, Treasury

Proposed Treasury Regulations Clarify UBTI “Silo” Rule

May 20, 2020 By Clay Littlefield, Daniel Reach, George Abney and Mark Williamson

Nearly two years ago, in the wake of the Tax Cuts and Jobs Act, the IRS issued interim guidance on the unrelated business taxable income (UBTI) “silo” rules. Our International Tax Group examines recently released proposed Treasury Regulations that largely follow, and partially expand, that guidance. Special rules for investment activities, including “qualified partnership interests”Interactions with net operating loss rules, as modified by the TCJA and the CARES ActEffects on Subpart F, GILTI, and other rules For the full advisory, click here. [...]Read more

Filed Under: Uncategorized Tagged With: CARES Act, Controlled Entities, Deb-financed properties, GILTI, IRS, NAICS, NOLs, partnership, QPI, S Corp, Schedule K-1, Subpart F, TCJA, Treasury, UDFI

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401(k) ACA Affordable Care Act audit BEAT CARES Act CFC Corporate Tax Planning covid-19 Delaware Department of Treasury Escheat FATCA FBAR FDII Gift cards GILTI international tax IRA IRS Kelmar New York nexus OECD qualified plans Quill RUUPA SCOTUS Section 351 Section 355 Section 367 Section 385 section 482 section 965 State legislation Subpart F Supreme Court Tax Court Tax Cuts and Jobs Act tax reform TCJA Treasury Unclaimed property UP Wayfair

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Recent Posts

  • How to Price in a Pandemic: New OECD Guidance on Transfer Pricing Challenges Caused by COVID-19
  • IRS Issues CARES Act Guidance Addressing Tax Issues Prevalent in M&A Transactions
  • Letter Ruling Conjures Ghost of Section 958(b)(4) Past
  • Sourcing the Source of Inventory Sales – Final Regulations Under Section 863(b)
  • Crystal Ball Gazing for the Federal Estate and Gift Tax After 2020 – Should I Act Now?

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