Tax Computation

Topics

December 1, 2009

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.

October 1, 2009

Last-Minute Estate Planning for 2009: Focus on the GST

This article focuses on estate planning opportunities relating to the generation-skipping transfer tax that practitioners and taxpayers should consider for implementation in 2009.

October 1, 2009

Check-the-Box Regs. Do Not Affect the Valuation of LLC Interests

The Tax Court held that limited liability company (LLC) interests transferred by a taxpayer into trusts set up for the benefit of her children should be valued as transfers of LLC interests and not as transfers of the underlying assets owned by the LLC.

September 1, 2008

Significant Recent Developments in Estate Planning

This article examines developments in estate, gift, and generation-skipping transfer tax planning and compliance between June 2007 and May 2008.

June 1, 2008

IRS Issues Prop. Regs. in Response to Kohler Case

The IRS has issued proposed regulations clarifying that under Sec. 2032 an estate may take into account a reduction in the value of the gross estate following the decedent’s death in determining the value of the estate on the alternate valuation date if the reduction is due to market conditions but not other post-death events.

January 1, 2008

Ninth Circuit Affirms Transferred Residential Property Must Be Included in Gross Estate

The Ninth Circuit ruled that the full fair market value of residential property must be included in the decedent’s gross estate, finding that the decedent retained income and economic enjoyment from the property and that the inter vivos transfer of the property was not a bona fide sale for adequate and full consideration under Sec. 2036(a).

September 1, 2007

Significant Recent Developments in Estate Planning

This article examines developments in estate and gift tax planning and compliance between June 2006 and May 2007.

September 1, 2007

Courts Split over Valuation of Lottery Prize Payments

Two recent district court decisions have been handed down on the issue of whether an estate’s rights to a decedent’s remaining series of annual lottery prize payments should be valued using the Sec. 7520 annuity tables. Although both courts held that the lack of marketability of remaining lottery payments may