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.
Tax Computation
Full value of GRAT includible in estate
The full value of a GRAT is includible in the grantor’s estate under Sec. 2036(a).
Gift and GST returns added to postponed tax and filing deadlines
The IRS postponed the payment and return filing requirements for gift and generation-skipping transfer taxes due April 15 to July 15, matching prior postponements granted to federal income taxes and returns.
Recent developments in estate planning: Part 1
This article is the first of two parts of an annual update on developments in trust, estate, and gift taxation. Part 1 discusses developments affecting trusts and the generation-skipping transfer tax, as well as inflation adjustments.
Recent developments in estate planning: Part 2
This article is the second of two parts of an annual update on developments in trust, estate, and gift taxation. It covers generation-skipping transfer tax and trust tax developments, as well as inflation adjustments for 2018.
Recent developments in estate planning: Part 2
This second of a two-part article discusses GST tax and trust tax developments, as well as tax reform proposals and inflation adjustments for 2017.
Valuation of family-owned entities for estate and gift tax purposes under Sec. 2704
This article discusses the rules governing the effects of lapses and restrictions on voting or liquidation rights of owners on the valuation of family-held entities.
How to fix an incorrect GST exemption allocation
The ability to obtain relief ensures that an individual’s GST exemption can be allocated correctly to certain transfers in trust.
IRS Permits Same-Sex Couples to Recalculate Marital Exclusion Amounts
The IRS spelled out the procedures same-sex married couples should use to recalculate the transfer-tax treatment for property transferred to spouses before the U.S. Supreme Court invalidated Section 3 of the Defense of Marriage Act.
Recent Developments in Estate Planning: Part 2
This is the second part of a two-part article examining developments in estate, gift, and generation-skipping transfer tax, and trust income tax.
Estate Valuation Discounts Would Be Prohibited Under Proposed Regulations
The IRS issued long-awaited proposed regulations designed to prevent taxpayers from lowering the estate and gift tax value of transferred assets.
Proposed Regulations Would Affect Estate Valuation Discounts
The IRS issued long-awaited proposed regulations designed to prevent taxpayers from lowering the estate and gift tax value of transferred assets.
Estates Have Until June 30 to File Estate Basis Form
The IRS announced one last postponement in the due date for filing under rules requiring reporting of the value of an estate’s assets to the IRS and beneficiaries.
Estate Basis Consistency Reporting Rules Are Proposed
The regulations reiterate the delayed reporting deadline of March 31, 2016.
Consider Combining the Tax Benefits of a Preferred Family Limited Partnership With a GRAT
Certain high-net-worth clients might achieve better results by using a preferred family limited partnership rather than an intentionally defective grantor trust or a grantor retained annuity trust.
Recent Developments in Estate Planning (Part 2)
This is the second of a two-part article examining developments in estate, gift, trust, and generation-skipping transfer taxes between June 2014 and May 2015.
Recent Developments in Estate Planning: Part 1
This is the first in a two-part article examining developments in estate, gift, and generation-skipping transfer tax and trust income tax between June 2013 and May 2014.
Gift Determined With Reference to Assumption of Potential Estate Tax Liability
In a departure from its own precedent, the Tax Court held that the fair market value of a donor’s taxable gift may be determined with reference to the donee’s assumption of the potential Sec. 2035(b) estate tax liability for the gift.
IRS Oversight of CPAs Who Provide Valuation Services
With the enactment of Sec. 6695A, the IRS was given new responsibilities to ensure the quality of appraisals and appraisers who provided information in support of a taxpayer’s federal tax filings.
Tax Court Holds Assumption of Estate Tax Liability May Reduce Value of Gift
The Tax Court denied an IRS motion for summary judgment in an estate and gift tax case where the taxpayer made gifts to her daughters while requiring them to pay any tax liability that would have been due if the taxpayer had died within three years of making the gifts.
