1、本科毕业论文（设计） 外 文 翻 译 原文 ： Variable pay Tax Planning for Uncertain Times: Opportunities, Flexibility, and the Long View With Congress struggling to come to grips with the politically thorny expiration of the so-called Bush tax cuts, CFP practitioners are grappling with both shorter and longer-term tax
2、planning opportunities for their clients. At the same time, planners are also encouraging clients to weigh important non-tax variables when plotting out wealth-building strategies. Whatever the outcome of the immediate ideological battle in Washington over federal marginal income tax rates and brack
3、ets, in 2013, higher income earners will face a pair of tax hikes that were enacted as part of the Patient Protection and Affordable Care Act of 2010 (PPACA) that may shape tax planning strategies for some clients. In addition, some observers believe that its only a matter of time before efforts to
4、chip away at the national debt and narrow the federal budget gap will include calling on higher earners to increase their share of the national tax. The Obama Administration has made $200,000 in income for individuals and $250,000 for married couples the new definition of rich in America, CFP, chief
5、 planning officer for spiriting, the San Francisco-based wealth management firm. Those income levels were proposed as the cut-off point above which taxpayers would not benefit from any extension of the Bush tax cuts. Health Reforms Tax Bite Those same income levels were included in PPACA. Specifical
6、ly, the health reform law adds nearly 1 percent to the employee portion of the Medicare payroll tax for higher income taxpayers, bringing the total to 1.45 percent (up from 0.9 percent), notes Russell Hall, a senior consultant for Towers Watson, an international compensation and human resource strat
7、egy consulting firm. In addition, unearned income of those same taxpayers will be subject to a 3.8 percent Medicare surtax in 2013, Hall says. Another important tax planning consideration is the consensus opinion that preferential tax treatment for long-term capital gains will remain embedded in the
8、 Internal Revenue Code, even if the maximum rate rises significantly above todays 15 percent ceiling. But even after the fog obscuring future capital gains and ordinary income tax rates lifts in Washington, planners will rely on analytical skills and reject rules of thumb to steer their clients towa
9、rd the most tax efficient wealth accumulation tactics and strategies. For example, planners are evaluating the trade-off between the value of deferring income in a tax-sheltered savings vehicle and paying taxes on income currently (versus an assumed higher future rate). John honey, CFF, Financial Ad
10、visors, was spinning out scenarios for corporate executive clients when it appeared highly probable that top earners would be facing a 39.6 percent top federal bracket beginning in 2011, versus 35 percent in 2010. Suppose a married executive with family taxable income exceeding $250,000 had the opti
11、on of taking a $100,000 bonus in 2010, or deferring it until 2013, he suggests. If the executive let that $100,000 gather notional interest at 4 percent annually in a nonqualified deferred compensation plan, it would grow to $112,486 in three years, Hoch says. But the combination of an assumed 39.6
12、percent basic marginal tax rate beginning in 2011 plus the higher Medicare tax rates that kick in two years afterward would leave that executive with only $63,667 after the federal tax bite in 2013. He would have way more money if he paid the tax in 2010 and invested it, concludes. Focus on Executiv
13、es Corporate executives (with both publicly and privately held companies) like hypothetical client, with access to nonqualified deferred comp plans, equity-based compensation, and other benefits, give planners a variety of tax planning issues to consider. That is particularly true when the client ha
14、s sufficient clout with senior corporate leadership to make adjustments to the structure of his or her compensation package. In a nonqualified plan, you the corporation can pick and choose anyone you want to confer benefits, and you can structure the compensation any way you want, notes Paul Schneid
15、er, J.D. However, as a practical matter, the larger the corporation, the harder it might be for an executive to negotiate a customized, tax-advantaged package. The larger companies tend to operate on general principles, so it makes it difficult to draw up different plans for different executives. An
16、d the administrative factors become more of a factor than anything else, Schneider says. Still, that doesnt mean that executives shouldnt try to negotiate the most favorable compensation arrangements possible, he adds. For executives with public companies, equity-based compensation schemes are, of c
17、ourse, a critical element of the capital accumulation game plan and present different tax-planning challenges and opportunities. The general expectation that long-term capital gains will be taxed at lower rates than ordinary income continues to steer executives towards equity-based compensation, eve
18、n if there may be an element of ordinary income when you start out, Schneider says. The long-term prospect of getting capital gain is more attractive than getting deferred compensation in the form of cash. Stock Option Opportunities Incentive stock options allow their holders to pay long-term capita
19、l gains tax rates on the spread between the exercise Price and the market price when they are sold-provided that the executive holds on to the shares for a year from the exercise date, and two years from the date they were granted. One down-side from the companys point of view, however, is that it cant take a deduction for the value of the employees gain when the ISO are exercised. In addition, because ISO are an element of a qualified plan, they are subject to a host of 1RS restrictions. For example, ISO must be part of a formal, written plan that spells out the
