A depressed market like in 2022 and possibly 2023 represents an opportunity to make late allocations of generation-skipping transfer (GST) tax exemption to prior years’ gifts. This opportunity arises when an asset's value has declined since the actual date of the gift and can result in significant transfer tax savings.

Buckle your seat belt and lift your tray table, the 2022 tax year was the last time 100% bonus depreciation was generally available for the purchase of a private aircraft. However, with a phase-down in increments of 20% until 2027, it will be a slow descent until the time when the bonus depreciation deduction is no longer available. It will be an even softer landing for an aircraft that qualifies as longer production period property (LPPP) and for certain aircraft placed in service after December 31, 2022, for which the bonus depreciation phaseout periods are extended by one year.

Perhaps the year 2022 will be remembered as the beginning of the transition to relative normalcy following the dramatic lifestyle changes resulting from the COVID-19 pandemic in 2020 and 2021. For instance, in 2022, staycations were replaced with revenge travel; mostly empty sports venues with posters of fans were replaced with sports venues filled with real fans; and tax filing deadlines returned to their standard dates.

The economic landscape in 2022 was driven by the Federal Reserve's steadfast commitment to combating high inflation with fast-paced monetary tightening. The Fed's efforts have resulted in a challenging investment period for both stocks and bonds. A balanced global portfolio with 60% stocks and 40% bonds was down approximately -20% through the end of October. Expectations are for the Fed to continue its restrictive policy for the near future, which leaves investors facing a challenging backdrop including a potential global recession and slowing economic growth.

The U.S. Inflation Reduction Act (IRA) allocates nearly $80 billion in new funding to the Internal Revenue Service (IRS). More than $45 billion of that amount is dedicated to compliance enforcement efforts with additional amounts for operations, systems modernization, and taxpayer service. The substantial increase in IRS enforcement funding, along with technology investments, is expected to result in additional scrutiny of transfer pricing arrangements. Multinational entities should take steps now to support their transfer pricing positions and explore opportunities for advance tax certainty.

Andersen Managing Director Joe Calianno's comments were included in the recent Tax Notes article, IRS Appears to Favor Aggregate CFC Adjustment for Corporate AMT.

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