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 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 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 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.
This article examines developments in estate, gift, and generation-skipping transfer tax planning and compliance between June 2007 and May 2008.
The gift of an LLC interest generally does not result in the recognition of gain or loss by the donor or the donee.