Foreign trust DNI, UNI, and the throwback rules: Important tax planning strategies
Foreign nongrantor trusts with U.S. beneficiaries have always been highly regulated under the throwback rules .
Estates
Recent developments in estate planning: Part 2
This second of a two-part article discusses GST tax and trust tax developments, as well as tax reform proposals and inflation adjustments for 2017.
Reporting foreign trust and estate distributions to U.S. beneficiaries: Part 1
Part 1 (of three) explains the classification criteria of a foreign nongrantor trust or foreign estate for U.S. tax purposes and the proper information reporting after U.S. taxes are withheld.
IRS allows certain estates an extension of time to make portability election
In a taxpayer-friendly development, the IRS issued guidance permitting certain estates to make a late portability election if they did not make a timely election.
Recent developments in estate planning: Part 1
This first of a two-part article discusses gift and estate tax developments.
Disclaimers as a fix for old trusts
The use of a disclaimer by a trust beneficiary may be helpful to adjust the results of a previously established irrevocable trust.
IRS provides simplified method to request an extension of time to make a portability election
In a taxpayer-friendly development, the IRS issued guidance permitting certain estates to make a late portability election if they did not make a timely election.
Estate planning for blended families
This column discusses AB trusts and ABC trusts.
Valuation of family-owned entities for estate and gift tax purposes under Sec. 2704
This article discusses the rules governing the effects of lapses and restrictions on voting or liquidation rights of owners on the valuation of family-held entities.
Sale of a residence in a QPRT
This item explores what happens if the residence is sold during the QPRT term.
IRS notice permits recalculation of marital deductions for same-sex couples
The IRS provided the procedures same-sex married couples should use to recalculate the transfer-tax treatment for property transferred to spouses.
How to fix an incorrect GST exemption allocation
The ability to obtain relief ensures that an individual’s GST exemption can be allocated correctly to certain transfers in trust.
Self-dealing exception solves estate settlement woes
An exception to the prohibition on indirect self-dealing can enable executors and families of decedents to conduct certain transactions with foundations without triggering penalties associated with self-dealing.
IRS Permits Account Transcripts to Replace Estate Tax Closing Letters
Because it no longer automatically issues an estate tax closing letter, the IRS announced that an account transcript can substitute for a closing letter.
IRS Permits Same-Sex Couples to Recalculate Marital Exclusion Amounts
The IRS spelled out the procedures same-sex married couples should use to recalculate the transfer-tax treatment for property transferred to spouses before the U.S. Supreme Court invalidated Section 3 of the Defense of Marriage Act.
Account Transcripts Can Substitute for Estate Tax Closing Letters
Account transcripts that contain a specific transaction code and wording can serve as the equivalent of an estate tax closing letter.
Theft Loss Eligibility Is Broader for Estates Than for Individuals
For estates, fraud loss need only to have arisen from theft to qualify for a theft deduction.
2017 Inflation Adjustments and Tax Tables for 2018 Filing Season Released
IRS issued the annual inflation adjustments for 2017 for more than 50 tax provisions as well as the 2017 tax rate tables for individuals and estates and trusts.
Estate Can Take Theft Loss Deduction Related to Madoff Ponzi Scheme
An estate could take a theft loss deduction where a Ponzi scheme rendered an interest in an LLC the estate owned worthless.
QTIP Election Permitted Together With Portability
The IRS will treat a QTIP election as valid in certain situations, including where an executor of an estate makes a portability election to transfer the decedent’s unused applicable exclusion amount.
