Читать книгу 2012 Estate Planning - Martin Inc. Shenkman - Страница 53

Consider the possible impact of several of these changes. A 50-year-old socialite-executive in New York earning a nice salary may lose a substantial charitable contribution deduction for the myriad of wonderful local charities he or she supports, a significant state and local tax deduction, and have to add to income a large amount for his or her health insurance plan if a new cap on what can be excluded is provided for. The new Medicare tax on earnings and investment income may be triggered.

Contrast this with a retiree living in Florida with a comparable income, but no state income tax. This taxpayer might face a relatively low actual marginal income tax rate, even if the Medicare tax on investment income is added. The bottom line difference on these two taxpayers could be dramatic.

High-tax state fence sitters may well be pushed by the net cost of eliminating a state income tax deduction to finally get off the fence and move to a no/low tax state. Residency and domicile issues could become even more significant planning factors.

Use of C corporations to trap income, similar to the personal holding companies (PHCs) of not so many years ago, may again become popular, at the cost of a big income tax hit when the entities are unwound later.