US estate tax: Not just for US citizens
The application of U.S. estate tax laws to a non–U.S. citizen depends on domicile, situs of assets, and application of a treaty.
Taxation of Estates & Trusts
10 estate and income tax questions
This item discusses 10 important income tax questions to consider when creating an estate plan.
No basis step-up for grantor trust assets if not in grantor’s estate
In a revenue ruling issued Wednesday, the IRS confirms that the step-up in basis under Sec. 1014(a) does not apply to the assets held by an irrevocable grantor trust when the grantor dies if the grantor’s gross estate does not include the assets of the irrevocable trust.
Recent developments in estate planning: Part 3
In this third installment of an annual update on trust, estate, and gift taxation, the topics include generation-skipping transfer tax, trusts, private foundations, selected inflation-adjusted amounts, and the president’s and Treasury’s proposed law changes affecting trusts, estates, and gifts.
Taxpayer’s argument for $1.5 million refund fails on several grounds
A taxpayer is not entitled to a refund under the claim-of-right doctrine, mitigation provisions, or doctrine of equitable recoupment.
2022 Arthur J. Dixon Memorial Award
G. Edgar “Eddie” Adkins Jr., CPA, received the 2022 Arthur J. Dixon Memorial Award, the highest honor bestowed by the accounting profession in the area of taxation.
Recent developments in estate planning: Part 2
In this second installment of an annual update on trust, estate, and gift taxation, the topics include split-dollar life insurance arrangements, indirect gifts, formula clauses in transfers of limited partnership interests, valuation discounts, and grantor retained annuity trusts.
Recent developments in estate planning: Part 1
In this first installment of an annual update on trust, estate, and gift taxation, the topics include estate tax closing letters, the basic exclusion amount, estate debts and expenses, and extending the time to elect portability.
Updated simplified method for estate portability elections
The IRS released Rev. Proc. 2022-32, which updates and expands the simplified method for estates to obtain an extension of time to make a portability election under Sec. 2010(c) (5)(A).
Estate planning update: Summary of recent proposed regulations
This item summarizes the impact of two sets of proposed regulations issued by Treasury in early 2022.
Estates can now request late portability election relief for 5 years
The IRS extended to five years the period under which a taxpayer can use a simplified method (in lieu of a letter ruling request) to obtain an extension of time to make a portability election.
Regs. proposed for present value of estate deductions
Administrative expenses and claims against estates allowable under Sec. 2053 beyond a three-year grace period would be discounted for current deduction, under proposed rules issued by the IRS.
Trusts as S corporation shareholders
Generally, a trust cannot hold stock of an S corporation; however, grantor trusts, testamentary trusts, voting trusts, ESBTs, and QSSTs are permissible S corporation shareholders (Sec. 1361(c)(2)).
Trusts for holding S corporation interests: QSSTs vs. ESBTs
This article compares the relative advantages and disadvantages of a QSST versus an ESBT in estate planning.
Freezing stock value with a corporate recapitalization
A corporate recapitalization can freeze the value of the owner’s stock, potentially reducing the owner’s estate tax liability by removing future appreciation in the value of stock from the owner’s estate.
Tax Court determines value of receivable from a split-dollar life insurance arrangement
The value of a receivable created by split-dollar life insurance arrangements is the receivable’s value, not the cash-surrender value of the insurance purchased under the arrangements
IRS proposes to amend estate and gift tax basic exclusion regs.
Exceptions to the special rule allowing the temporarily higher basic exclusion amount to apply to gifts credited against estate tax.
10 common Form 709 mistakes
While it may take some finesse to report the most complicated transactions on Form 709, you do not have to be a gift tax specialist to be aware of 10 common return preparation mistakes.
Tax issues that arise when a shareholder or partner dies
This article discusses what partnerships, S corporations, and their owners need to know to manage the tax risks that arise when an individual partner or shareholder dies.
Indirect gift tax considerations for 2021
It is important to consider some of the less-obvious gifts when you are advising clients who are intent on using up their full $11.7 million basic exclusion amount before the end of the year.
