IRS simplifies procedure to request relief for late portability elections
This article discusses the relief available when an executor misses filing the election to make estate exclusion amount portable.
Estate Tax
Reporting foreign trust and estate distributions to U.S. beneficiaries: Part 2
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.
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.
Recent developments in estate planning: Part 1
This first of a two-part article discusses gift and estate tax developments.
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.
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.
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.
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.
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.
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.
Tax Planning Opportunities for Tax Attributes and the Decedent’s Final Tax Return
Careful and thoughtful advanced planning can result in substantial tax savings.
Understanding Qualified Domestic Trusts and Portability
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.
Consistent Basis Reporting Between Estates and Beneficiaries
Executors and practitioners will have to deal with questions and inconsistencies until the IRS addresses them.
Estate Valuation Discounts Would Be Prohibited Under Proposed Regulations
The IRS issued long-awaited proposed regulations designed to prevent taxpayers from lowering the estate and gift tax value of transferred assets.
Late Portability Elections After the Expiration of Rev. Proc. 2014-18
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.
Guidance Allows QTIP Election Where Executor Elects Portability
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.
Recent Developments in Estate Planning: Part 1
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.
Proposed Regulations Govern Estate Basis Consistency Reporting
The regulations provide rules regarding the consistent basis reporting requirement and the required statement that must be furnished to the IRS and beneficiaries.
Post-Death Events Taken Into Account in Property Valuation
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.
Executor Not Liable as Fiduciary for Unpaid Estate Tax
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.
