Fiduciary Fee Unbundling Rules Delayed Until 2015
In response to a comment that the current effective date of the new rules on fiduciary fees does not give fiduciaries enough time to implement them, the IRS amended T.D. 9664 to delay the date.
Administration expenses
Final Sec. 67(e) Regulations: The End of a Long Journey
Sec. 67(e) reached the end of a long and tortured journey recently, when the IRS issued final regulations defining, once and for all, which expenses of an estate or trust are classified as miscellaneous itemized deductions subject to the 2% floor and the alternative minimum tax.
Effective Date of Fiduciary Fee Unbundling Rules Delayed Until 2015
The new rules governing which costs of trusts and estates are subject to the 2% floor on miscellaneous deductions now apply to tax years beginning after Dec. 31, 2014, rather than to tax years beginning on or after May 9, 2014.
Final Regs. on Trust Expenses and 2% Floor on Miscellaneous Itemized Deductions
The IRS issued final regulations on the controversial question of which costs incurred by trusts and estates are subject to the 2% floor on miscellaneous deductions under Sec. 67(a).
Final Rules on Fiduciary Fees Are Issued
The IRS issued final regulations on the controversial question of which costs incurred by trust and estates are subject to the 2% floor on miscellaneous deductions under Sec. 67(a).
Trust Deductions: Knight, Prop. Regs. Still Govern
Preparers of fiduciary tax returns for tax years 2011 and 2012 will not be required to unbundle fiduciary fees, but they still must treat payments readily identifiable as subject to the 2% floor separately from a bundled fiduciary fee.
IRS Proposes New Rules for Deducting Fiduciary Fees
The IRS issued proposed regulations intended to reflect the Supreme Court’s 2008 holding in Knight on income tax deductibility by estates and nongrantor trusts of investment advisory and other fees.
Guidance on Unbundling Trustee Fees Extended
The IRS announced that it is extending interim guidance on the treatment of investment advisory fees and other costs subject to the 2% floor under Sec. 67(a).
IRS Extends Guidance on Trustee Fees
The IRS announced that it is extending interim guidance on the treatment of investment advisory fees and other costs subject to the 2% floor under Sec. 67(a).
Trustee Compensation: Proceed with Caution
This item illustrates the issues that can lead to litigation on trustee compensation.
Prop. Regs. Address Deductibility of Trust and Estate Costs
Editor: Kevin F. Reilly, J.D., CPA In July, the IRS issued proposed regulations (REG128224-06) providing guidance on whether costs incurred by estates or nongrantor trusts are subject to the 2% floor for miscellaneous itemized deductions. The new rules intend to clarify the deductibility of advisory fees paid by estates and
Prop. Regs. Clarify Treatment of Trust Administrative Expenses
Under Sec. 67(a), miscellaneous itemized deductions are allowed only to the extent that they exceed 2% of a taxpayer’s adjusted gross income (AGI). The AGI of an estate or trust is computed in the same manner as for an individual for these purposes, except that, under Sec. 67(e)(1), administrative costs
Rudkin Files Supreme Court Petition
On March 23, 2007, the Rudkin Testamentary Trust petitioned the Supreme Court to resolve the split in the circuits over whether Sec. 67(e) allows estates and trusts to fully deduct investment management fees. (The American Bankers Association will also file an amicus brief.) The Second Circuit created a three-way split
Did the Second Circuit Err in Rudkin Testamentary Trust?
This article examines how the Second Circuit reached its decision and how trustees and practitioners should respond to this questionable ruling.
