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.
The IRS released the final 2010 version of Form 709, United States Gift (and Generation-Skipping Transfer) Tax Return, and its instructions.
In Fisher, the IRS has again won on the issue of whether taxpayers’ transfers of partnership interests were transfers of present interests in property. The court held the transfers did not qualify for the gift tax annual exclusion.
This item describes the use of the grantor-retained annuity trust (GRAT) in estate and gift planning.
This discusses the estate tax, generation-skipping transfers, trusts, changes made by the Economic Growth and Tax Relief Reconciliation Act of 2001, and the annual inflation adjustments for 2010 relevant to estate and gift tax.
This article examines developments in estate, gift, and generation-skipping tax planning and compliance between June 2009 and May 2010.
This article addresses various issues that may arise in the preparation of federal gift tax returns, with a focus on gift tax returns that will be filed to report gifts made during 2009 or 2010.
The IRS clarified for taxpayers that despite the provisions of Sec. 2511(c), the gift tax continues to apply to certain transfers to a wholly owned grantor trust.
The Tax Court held, in Price, T.C. Memo. 2010-2, that taxpayers were not entitled to annual gift tax exclusions under Sec. 2503(b) for the outright gifts of partnership interests.
The Tax Court ruled that the check-the-box (CTB) regulations do not apply for purposes of valuing the transfer of property held through a single-member limited liability company (LLC) for federal gift tax purposes.