President’s fiscal year 2014 budget contains numerous tax provisions - President Barack Obama released his proposed budget for the government’s fiscal year 2014 on April 10, 2013, and, not surprisingly, the budget...more
Most people who are born in the United States or who purposely become citizens here know they are U.S. citizens. But many people who’ve spent their lives abroad and are citizens of other countries may be shocked to learn that...more
Code §2703 severely restricts the ability of a buy-sell agreement to control estate tax values in a closely held entity. A recent private letter ruling reminds us that older agreements are not subject to Code §2703....more
In This Issue: - February Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - IRS Issues Revenue Procedure 2013-15 - Private Letter Ruling...more
On January 1, 2013, the Senate and the House of Representatives passed the American Taxpayer Relief Act of 2012 (ATRA), averting the so-called “fiscal cliff.” The legislation, which was signed by President Obama on January 2,...more
For federal estate and gift tax purposes. This was the figure projected by some tax service publications – now the IRS concurs....more
On January 1, 2013, President Obama signed into law the American Taxpayer Relief Act of 2012 (the “2012 Act”) that was passed by Congress during the past 72 hours, bringing closure to the main tax aspects of the so-called...more
In a recent Chief Counsel Advice, a taxpayer made a gift in the prior year, but did not file a gift tax return. The taxpayer later died. On the estate tax return for the taxpayer, the earlier unreported gift was reported....more
In This Issue: - December Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - Estate of Thouron v. United States, E.D. Pa., No. 2:11-cs-04058...more
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