Tax Planning; Tax Minimization

Interim Guidance Issued on Unbundling Trustee Fees

The IRS announced that for tax years beginning before January 1, 2008, nongrantor trusts and estates will not be required to unbundle their fiduciary fees to determine what portion is subject to the Sec. 67(a) 2% threshold for itemized deductions.

The Ongoing Sec. 67(e) Controversy and the New Preparer Penalties

This item discusses how the 2% floor affects a trust’s regular tax and alternative minimum tax (AMT), the effect of the recent Supreme Court decision in Knight on the continuing controversy, and the efficacy of the proposed regulations in the wake of the Knight decision.

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

Newsletter Articles


2020 tax software survey

COVID-19 upended tax season. Did CPAs’ tax software help them cope? Read the results of our annual tax software survey


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.