Securities Tax Wills, Trusts, & Estate Planning

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Tax Court Rules on Built-In Gains Discount and Appraiser Qualification

On February 11, 2014, the United States Tax Court issued a memorandum opinion (i) determining the proper method for valuing a holding company (i.e., an S or C corporation holding marketable securities or appreciated...more

Updated PFIC And CFC Definitions And Reporting Rules

The IRS has issued updated reporting regulations under Code Sections 1291, 1298, 6038 and 6046. A lot of the changes are technical definitions, and relate to updates from proposed regulations going back to 1992. ...more

Discerning the true settlor of a trust

The person designated in the terms of a trust as its settlor (creator) may not necessarily be its true settlor (creator). Appearances are often deceiving in the world of the trust. Charles E. Rounds, Jr. explains in §8.43 of...more

Beware: Active Participation of Trustee S-Corporation Shareholder is Required – Technical Advice Memorandum 201317010

Differing points of view have arisen regarding determining the active participation of S-Corporation shareholdings held in Trust....more

Planning for Carried Interests & Avoiding Section 2701

Alternative investments in private equity and hedge funds have gained in popularity over the last two decades and have become a regular allocation of many investment portfolios....more

"With Iron Mountain Ruling, IRS Continues Consistent Approach to Defining REIT ‘Real Estate’"

A significant amount of press attention has been given to an unusual press release filed with the SEC yesterday by Iron Mountain regarding its planned conversion to a real estate investment trust (REIT). Iron Mountain said...more

Tax Talk -- Volume 5, No. 4 -- January 2013

In This Issue: Fiscal Cliff Diving a.k.a. American Taxpayer Relief Act; CoCo Developments; Tax Effect of Money Market Fund Proposals; IRS Issues Final Regulations on Publicly Traded Property; Assessment of Income from...more

Now That the Election Is Over, How Do You Plan for 2013’s New Tax on Investment Income?

Originally published in Daily Tax Report on December 3, 2012. President Obama’s re-election and the Democrats’ retained control of the Senate mean that a repeal of the Patient Protection and Affordable Care Act before...more

Unpaid Federal Taxes, Lead to Federal Tax Liens

Proving that celebrities are not above the law, the IRS recently served rapper Lil’ Kim with a tax lien for allegedly dodging more than $1 million in taxes. While it is celebrity tax stories that most often make the...more

Regression Models and Discount for lack of Marketability

Recent publication of the Discount for Lack of Marketability(DLOM) Job aid for IRS Valuation Professionals has brought fresh scrutiny to the various methods used by valuation practitioners for determining discount for lack of...more

High Net Worth Family Tax Report, Vol. 6, No. 2

In This Issue: Table of Contents: California Enacts Legislation Requiring Out-of-State Retailers to Collect Use Tax; SEC Finalizes Rules Exempting Family Offices from Requirement to Register as Investment Adviser;...more

Mofo Tax Talk - Volume 3, No. 4 - January 18, 2011

In this issue: 2010 Tax Relief Act; Knock-Out Option Treated as Direct Ownership of Underlying; Tax System Overhaul Recommended by Deficit Reduction Commission; Proposed Regulations Clarify and Expand Scope of “Publicly...more

Two More Reasons to Consider Converting Your IRA to a Roth IRA Before Year End

This year – 2010 – has been the year of the Roth IRA, with new rules in place permitting taxpayers in any income tax category to convert their traditional IRAs to Roth IRAs. There has been a plethora of discussion and...more

Recent Economic Developments Affecting Your Personal Planning By Kathleen A. Ryan, Esq. Kimberly I. McCarthy, Esq. Megan C.N....

Excellent Estate Planning Opportunities in the Current Market: Due to exceptionally low interest rates, it is a great time to remove certain assets expected to appreciate in the future (such as marketable securities and...more

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