If the general partner has unfettered discretion to make or withhold distributions, any gift of an interest in the partnership may be treated as a gift of a future interest not qualifying for the annual gift tax exclusion.
The Tax Court held that a transfer for adequate consideration was not a gift
Taxpayers who receive gifts or bequests from individuals who gave up U.S. citizenship or residency will be subject to tax under proposed rules.
This is the second of a two-part article examining developments in estate, gift, trust, and generation-skipping transfer taxes between June 2014 and May 2015.
Taxpayers who receive gifts or bequests from certain individuals who gave up their U.S. citizenship or residency will be subject to tax under rules proposed by the IRS on Wednesday.
This is the first part of a two-part article examining developments in estate, gift, and trust income tax between June 2014 and May 2015. Part 1 discusses gift and estate tax developments.
The Tax Court held that the withdrawal rights provided in a trust declaration were not illusory and that therefore a married couple's gifts to the trust were gifts of present interests in property that qualified for the annual exclusion.
In the typical Crummey trust, a periodic contribution of assets to the trust is accompanied by an immediate withdrawal power that gives the beneficiary the right to withdraw the contribution for a limited time.
This is the first in a two-part article examining developments in estate, gift, and generation-skipping transfer tax and trust income tax between June 2013 and May 2014.
In a departure from its own precedent, the Tax Court held that the fair market value of a donor’s taxable gift may be determined with reference to the donee’s assumption of the potential Sec. 2035(b) estate tax liability for the gift.
The Tax Court denied an IRS motion for summary judgment in an estate and gift tax case where the taxpayer made gifts to her daughters while requiring them to pay any tax liability that would have been due if the taxpayer had died within three years of making the gifts.
This article examines developments in estate, gift, and generation-skipping transfer (GST) tax and trust income tax between June 2012 and May 2013.
The president's recently released FY 2014 proposed budget contains a number of estate, gift, and generation-skipping transfer (GST) tax proposals.
Dispository documents involving lifetime gifts or testamentary bequests often include formula clauses to designate the value of property passing by gift or bequest.
With thoughtful planning, taxpayers can minimize gift and estate taxes while retaining some control of transferred assets by establishing trusts or limited partnerships and using the annual gift tax exclusion.
The IRS released its annual revenue procedure making inflation adjustments to the gift tax annual exclusion and other items for tax years beginning in 2013.
This article covers recent developments in estate tax, including the portability election, proposed regs. on the alternate valuation date, FLPs.
This two-part article examines developments in estate planning and compliance between June 2011 and May 2012. Part I discusses developments regarding gift tax and trusts, an outlook on estate tax reform, and annual inflation adjustments for 2012 relevant to estate, gift, and generation-skipping transfer (GST) tax. Part II, in the October issue, will cover developments in estate tax.
This article covers gift tax, generation-skipping transfer (GST) tax, trust developments, and the annual inflation adjustments for 2011 relevant to estate and gift tax.
The lifetime gift tax exclusion increased to $5 million for 2011 and 2012, and there is concern that the IRS will attempt to assess either an additional gift tax or extra estate tax if the lifetime exclusion is subsequently reduced.