The revenue procedure advises taxpayers how to make various elections, file amended returns, and change accounting methods as provided under Section 70302 of the new law.
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TOPICS
Taxation of Estates & Trusts
Tax provisions of Senate Finance’s version of the budget bill
The 549-page text calls for making many provisions of the Tax Cuts and Jobs Act permanent. The committee says that the SALT cap amount is “the subject of continuing negotiations.”
Adequate disclosure on gift tax returns: A requirement for more than gifts
Specific requirements apply to the adequate disclosure of transactions on a gift tax return.
ING trusts: How they work and their continued viability
Properly established and maintained, an incomplete gift nongrantor trust may play a valuable role in some clients’ estate plans
IRS reduces user fee for estate tax closing letters
The receipt of an estate tax closing letter generally indicates that the estate tax return’s IRS examination is closed. Final and proposed regulations lowered the fee by $11.
Limiting the unlimited charitable deduction for trusts
Although Sec. 642(c) provides for an “unlimited” charitable income tax deduction attractive to philanthropic grantors, Sec. 681 may limit a trust’s actual deduction.
Estate tax considerations for non-US persons owning US real estate
Planning options include holding the U.S. real estate through legal entities or trust structures.
Early terminations of QTIP trusts: The cautionary case of McDougall
Qualified terminable interest property trusts can be useful, but care must be taken to avoid running afoul of their requirements, as a recent Tax Court case illustrates.
The final countdown: Benefiting from the higher BEA before it potentially expires
With the basic exemption amount for estate, gift, and generation-skipping transfer taxes set to be cut in half after the end of 2025, tax advisers can lead clients in planning and taking action now.
Final regs address taxes on gifts to taxpayers from ex-U.S. citizens, residents
The final regulations implement Sec. 2801, added to the Code in 2008, and follow up on proposed regulations issued 10 years ago.
Proposed regulations update QDOT regulations
Changes to the qualified domestic trust regulations under Sec. 2056A would include defining when the value of assets passing to the trust is “finally determined.”
Life insurance proceeds not includible in estate
Proceeds from life insurance on decedent not includible in his estate.
Connelly clarifies estate treatment of stock redemption
The Supreme Court held that a corporation’s stock redemption obligation was not a liability that reduced the corporation’s value for estate tax purposes.
Final regs. issued on consistent-basis and basis-reporting rules
The IRS issued guidance for recipients of property from decedents on the basis-consistency requirement and for executors and others on basis-reporting requirements.
Fact sheet addresses taxability of crowdfunding distributions
The IRS said that crowdfunding distributions may be included in the gross income of the person receiving them, depending on the facts and circumstances of the distributions.
A trust is not always a trust for federal income tax purposes
Whether an entity that purports to be a trust is treated as one or as a nominee depends on the facts and circumstances.
Supreme Court: Obligation to redeem stock was not a liability
The value on an estate return of shares in a closely held company were erroneously offset by the redemption obligation, the Court held.
Supreme Court: Insurance proceeds increase corporation’s estate tax value
In a unanimous decision, the Supreme Court holds that life insurance proceeds a corporation receives to fund a share redemption agreement increases the corporation’s estate tax value.
Recent CCA raises concerns for irrevocable grantor trust modifications
A Chief Counsel Advice memo holding that adding a tax reimbursement clause to an irrevocable grantor trust will constitute a taxable gift by the beneficiaries to the grantor raises a host of questions that taxpayers and advisers should consider before modifying a trust.
The Sec. 645 election to treat a trust as part of the estate
A Sec. 645 election can streamline tax reporting and offer other tax advantages when a client with a living revocable trust dies. Read about the requirements for making a Sec. 645 election, the tax benefits of making the election, and how and when to make the election.
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.
