Estate Tax
Part 2 of this three-part series analyzes legal and beneficial ownership concepts as applied to a trust or estate created and administered in a foreign common law jurisdiction in contrast to a civil law jurisdiction.
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.
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.
This first of a two-part article discusses gift and estate tax developments.
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.
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.
The IRS provided the procedures same-sex married couples should use to recalculate the transfer-tax
treatment for property transferred to spouses.
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 that contain a specific transaction code and wording can serve as the equivalent of an estate tax closing letter.
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.
This article discuses how transfer-tax rules for noncitizen spouses differ from the transfer-tax rules that apply to spouses who are U.S. citizens or residents.
Careful and thoughtful advanced planning can result in substantial tax savings.
Executors and practitioners will have to deal with questions and inconsistencies until the IRS addresses them.
This item discusses relief available to the executor of an estate that fails to elect portability by failing to timely file an estate tax return.
The IRS issued long-awaited proposed regulations designed to prevent taxpayers from lowering the estate and gift tax value of transferred assets.
The IRS removed a prohibition on making a qualified terminable interest property (QTIP) election when the election would have been null and void because the estate had a zero estate tax liability.
This is the first in a two-part series examining developments in estate, gift, and generation-skipping transfer tax and trust income tax. Part 1 discusses legislative and gift and estate tax developments.
The regulations provide rules regarding the consistent basis reporting requirement and the required statement that must be furnished to the IRS and beneficiaries.
The Tax Court held that the IRS had properly taken into account events that occurred after the decedent’s death in determining the value of property for purposes of an estate’s charitable deduction.
Practitioners who assist clients with preparing estate tax returns should make sure that they know the very real danger they face if distributions are made from the estate before all the federal estate taxes are paid.
