Polsinelli Podcast - Getting the Most Out of Your Estate Planning in 2014
The Greatest Gift: Your Individual + Family Estate Plan
The 2010 Tax Relief Act and your estate plan
Are your estate planning documents protecting your assets?
Same-Sex Marriage Cases in 90 Seconds
Should you Opt-Out of the Voluntary Disclosure Program?
Death and Foreign Asset Disclosure. What you don't know can cost you…a lot
Safeguard Your MVA: Devising a Business Succession Plan that will Preserve your Most Valuable Asset
Divorce can be costly, especially when it reveals undisclosed foreign assets.
Estate Planning: Wills, Trusts, & Power of Attorney in Arizona - Putting Family First
Foreign Asset Disclosure Program
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
This is a brief update on recent Pennsylvania tax developments. It is intended to provide an overview of issues and cases to watch, as well as administrative and legislative developments....more
January Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts -
The January § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more
This is a brief update on recent Pennsylvania tax developments. It is intended to provide an overview of issues and cases to watch, as well as administrative and legislative developments.
On August 29, 2013, the Internal Revenue Service ruled that married same-sex couples will be treated the same as married heterosexual couples for all federal tax purposes, including income and gift and estate taxes. Revenue...more
In the recent decision in Clearwater Seafoods Holdings Trust (2013 FCA 180), the Federal Court of Appeal considered the scope and purpose of Rule 29(1) of the Tax Court of Canada Rules (General Procedure) (the “Rules”). When...more
If a taxpayer does not file a tax return, the statute of limitations for most federal taxes never commences. Thus, in theory, the IRS can go back as many years it wants to such an “open” year to audit and assess tax....more
On January 25, 2013, trustees around the state breathed a sigh of relief after the Iowa Supreme Court reversed the district court’s controversial decision in the trust case of In the matter of Trust #T-1 of Mary Fay Trimble....more
Late 2012 saw an unprecedented amount of gifting, as taxpayers sought to use up their unified credit before it was slated to shrink up in 2013. As a result, the IRS should be swamped with gift tax returns for 2012. Taxpayers...more
I have previously written about the Wandry decision... Wandry is a favorable Tax Court Memorandum decision that accepted the use of a simplified formula gift clause (that is, one that did not involve disclaimer or charitable...more
To obtain a charitable deduction for many contributions of property, the taxpayer is required to obtain a “qualified appraisal” and submit that appraisal with the income tax return. Treas. Regs. §1.170A-13(c)(ii) contains a...more
EXECUTIVE SUMMARY: The U.S. District Court for the Southern District of New York has ruled that same-sex couples can take advantage of the estate tax marital deduction provisions of the Internal Revenue Code. This ruling has...more
In a recent U.S. District Court case, transferee liability statutes were favorably interpreted to avoid transferee liability to trust beneficiaries. However, the fiduciaries were unable to rely on a contribution agreement...more
For those of you with a great memory, you will remember that in December 2009 we wrote about the case of Morgens v. Commissioner. For those with a more typical memory, you can read the original post on the case here.
The U.S. Supreme Court recently held that an overstatement of basis did not trigger the extended six-year statute of limitations assessment period under Internal Revenue Code Section 6501(e)(1)(A) (United States v. Home...more
Less than a month after hearing oral argument on March 13, 2012, the Supreme Court of Canada today released judgment and reasons for judgment in the Fundy Settlement v. Canada also known as the Garron Family Trust appeals...more
In Garron Family Trust v. The Queen (2009 TCC 450), Justice Judith Woods of the Tax Court of Canada came down with a very broad new rule for determining the residence of trusts.
 I conclude, then, that the...more
The Supreme Court of Canada dismissed the taxpayers’ appeal in Fundy Settlement (also known as Garron or St. Michael Trust Corp.), deciding on April 12, 2012 that the relevant trusts were resident in Canada rather than...more
On March 21, 2012 the Tax Court of Canada issued judgment in the decision of McClarty Family Trust et al v. The Queen. The Minister of National Revenue (the “Minister”) had applied the general anti-avoidance rule (the “GAAR”)...more
In this memorandum opinion, the Court of Chancery appointed a receiver for an insolvent corporation deadlocked over how to discharge a tax lien.
Defendant Metropolitan Hospice, Inc. (“MHI”), a closely held corporation,...more
Earlier today, the Supreme Court of Canada heard arguments in the Garron appeal. The reasons for judgment of the Tax Court of Canada and the Federal Court of Appeal, as well as the factum of each party, may be found at our...more
In This Issue:
- February Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts
- IRS Issues Notice 2011-101
- IRS Issues Final Form 8938
In This Issue:
Settlment Offers: CIBC World Markets Inc. v. Her Majesty The Queen
Requirement to Provide SIN/BN on T5 - 3
Volunteer Rewards Program - 3
New Smart Chart Added - 4
Taxpayers that desire to contest an IRS assertion of tax liability in Federal district court or the Court of Federal Claims must first FULLY pay the asserted tax liability, and then sue for a refund. If the liability is high...more
A federal court judge has granted permission for a John Doe summons requested by the IRS to be served on California’s Department of Equalization (DOE) seeking information on taxpayers who allegedly tried to evade taxes when...more
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