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Potential Estate Tax Law Changes That Could Impact Ownership Transitio


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Possible changes to estate tax law could impact the timing of ownership's decision to sell the Bills. The current 35% tax rate might rise to 45% assuming it's part of the deal struck by the Adminstration and Congressional Republicans. This change would cost a $1 billion estate around $100 million in extra taxes. Is that enough to 'force' a sale via a capital gains route vs. the estate sale approach? Who can know for sure but it could introduce a new wrinkle in the ownership succession issue and produce a decision sooner than the current plan of waiting for a post mortem estate sale.

 

http://www.bloomberg.com/news/2012-12-11/buffett-joins-soros-in-effort-to-raise-taxes-on-estates.html

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Mary Wilson won't have to pay estate tax - spousal exemption. Wilson won't sell the team until he dies to avoid capital gains tax. Pick your poison, Wilsons alive and holds on to the team but nothing changes or he dies and team goes for sale and probably moves.

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Even if estate taxes increase by a huge amount, Ralph comes out ahead financially by keeping the team until his death. For a detailed explanation, see reply #28 in this thread:

 

http://forums.twobillsdrive.com/topic/153006-capital-gains-vs-estate-tax-ralph-should-sell-now/page__st__20estate

 

To slightly oversimplify, the federal estate tax is calculated based on Ralph's net worth at the time of his death. Whether he owns an $800 million NFL franchise, or has $800 million in cash in the bank, he will pay estate taxes based on the same $800 million net worth. Regardless of how estate tax rates may change between now and his death, any sale of the team before he dies triggers an ADDITIONAL capital gains tax, leaving him with a net worth of less than $800 million at the time of his death.

 

This assumes that Ralph will not leave the team to his wife, because he said he would not do that in his last public statement about the matter.

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Possible changes to estate tax law could impact the timing of ownership's decision to sell the Bills. The current 35% tax rate might rise to 45% assuming it's part of the deal struck by the Adminstration and Congressional Republicans. This change would cost a $1 billion estate around $100 million in extra taxes. Is that enough to 'force' a sale via a capital gains route vs. the estate sale approach? Who can know for sure but it could introduce a new wrinkle in the ownership succession issue and produce a decision sooner than the current plan of waiting for a post mortem estate sale.

 

http://www.bloomberg...on-estates.html

 

Between the increases they're discussing, and the surcharge already embodied in the ACA, capital gains taxes could likely be even more once DC is done.

 

Now we're all going to get banned for talking politics on the main board in 3...2...1...

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My friend thinks Ralph borrowed all the equity out of the Bills already. So when he goes all that's left to tax is a bunch of bank IOUs.

 

PTR

 

The Bills have approx $127 m in debt per forbes. Doesn't make too much sense to have borowed against all the equity, it still has to be paid back.

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Between the increases they're discussing, and the surcharge already embodied in the ACA, capital gains taxes could likely be even more once DC is done.

 

Now we're all going to get banned for talking politics on the main board in 3...2...1...

 

The capital gains issue is irrelevant seeing whoever inherits the assets will get a step up even if it goes to a trust. And yes between fed, state and the medicare tax of 3.8% for ACS cap gains will likely be more, or darn close to estate taxes. The challenge with either of these issues is providing liquidity to pay the taxes upon death. I really doubt Ralph has an irrevocable life insurance trust large enough to provide the liquidity. However that might explain why he borrowed equity. Borrow the equity and grow it over the years at a rate higher than the note and use that to pay the estate taxes. I think it's safe to say the planning is done and tied up with a cute little bow, but you never know.

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