Tax Computation

Recent Developments in Estate Planning: Part I

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.

Computing the Includible Portion for Graduated GRATs

Recent regulations provide practitioners a reminder that planning discussions with clients considering graduated GRATs should include a review of the potential consequences presented if the grantor dies prematurely

Important Lessons Regarding Valuation Issues

Taxpayers with high income and high net worth should be diligent regarding the valuation process and ensure they have used thorough and well-documented appraisal methodologies.

Final Regs. on Listed Transactions for GST Tax

The IRS issued final regulations that add transactions that reduce or eliminate the GST tax as listed transactions or transactions of interest and require the disclosure of those transactions under Sec. 6011.

Final Regulations Govern Listed Transactions for GST Tax

The IRS issued final regulations on Thursday that add transactions that reduce or eliminate the generation-skipping transfer (GST) tax as listed transactions or transactions of interest and require the disclosure of those transactions under Sec. 6011.

Preparing and Filing Form 8939

The IRS has issued Form 8939 and long-awaited guidance for executors of decedents who died in 2010 and who are deciding whether to elect out of the estate tax and apply the carryover basis rules of Sec. 1022.

A Valuation Discount Win for Estate Planners

There has been relatively little guidance on how LLCs should be treated for transfer tax purposes. However, in 2009 a case the Tax Court ruled in favor of the taxpayer that a transfer of an interest in an SMLLC should be valued as a transfer of an interest in the entity.

The Valuation of FLPs

Due to the popularity of family limited partnerships (FLPs) and the significant tax savings they can provide, the IRS has sought to limit the benefits of their use. As part of its attack on an FLP, the IRS frequently will challenge the value of the FLP that is claimed on an estate or gift tax return.

Gift and Estate Planning After Pierre

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.

Newsletter Articles

50th ANNIVERSARY

50 years of The Tax Adviser

The January 2020 issue marks the 50th anniversary of The Tax Adviser, which was first published in January 1970. Over the coming year, we will be looking back at early issues of the magazine, highlighting interesting tidbits.

TAX RELIEF

Quirks spurred by COVID-19 tax relief

This article discusses some procedural and administrative quirks that have emerged with the new tax legislative, regulatory, and procedural guidance related to COVID-19.