Estate Tax Internal Revenue Service

Estate taxes, also known as inheritance or death taxes, are taxes on an individual's right to transfer property at death.
News & Analysis as of

Income Tax Reporting for Decanting

Decanting refers to the distribution of trust property of one trust (the “first trust”) to another trust (the “second trust”). Over the past several years, the number of states specifically authorizing decanting by statute...more

Mi Casa es Su Casa! - Planning Considerations Non-Resident Aliens Purchasing a Home in America

Overview - In spite of our many problems as a nation, the quality of life and level of economic opportunity as well as the overall respect for the rule of law, places the United States in a very unique position when...more

High Net Worth Family Tax Report, Vol. 9, No. 1

In This Issue: - Congressman Camp Camp Releases His Long-Awaited Tax Reform Plan - Tax Court Addresses Valuation Issues Related to Tax on Built-In Corporate Gain - Shareholder of S Corporation Required to Include...more

IRS Grants Extension of Time to Take Advantage of Portability Election

The IRS has provided relief for persons who missed the opportunity to make a "portability election." To understand the importance of the relief, a review of the basics is in order....more

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

Estate Tax Audits for Large Estates Are a Virtual Certainty

What you need to know: Recent audit statistics show that federal estate tax returns are facing increased scrutiny from the IRS....more

It’s Not Too Late to Use Your Spouse’s Unused Estate Tax Exclusion

In Revenue Procedure 2014-18 the IRS provided an extension of time to those who wished to be sure that a decedent’s surviving spouse could benefit from the concept known as “portability”. In the Procedure, the IRS provides...more

IRS Guidance On Estate Tax Portability

The Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 amended the Internal Revenue Code to allow the estate of a decedent who is survived by a spouse to make a "portability election" which...more

Simplified IRS Relief for Same-Sex Couples and Others

On January 27, 2014, the Internal Revenue Service announced in Revenue Procedure 2014-18 a simplified procedure for certain estates to make a late portability election under section 2010(c)(5)(A) of the Internal Revenue Code....more

The Tax Man Cometh…A Recap

The IRS has released its “Estate Tax Returns Filed for Wealthy Decedents, 2003–2012” statics report. PK Law thought our readers would find some of the statistics enlightening....more

Equal Tax Treatment for Same-Sex Couples in the Wake of Recent Supreme Court Ruling and IRS Guidance

Same-sex marriages now are being recognized under federal tax law for the first time. In June 2013, the Supreme Court released its decision in United States v. Windsor, 530 U.S. 12 (2013), declaring Section 3 of the federal...more

High Net Worth Family Tax Report, Vol. 8. No. 4 -- December 2013

IRS Explains Federal Tax Consequences of Windsor Case Regarding Same-Sex Marriages - In our last report (Vol. 8, No. 3, September 2013), we told you about the recent Windsor case, in which the Supreme Court held...more

Marriage and Taxes in 2013

Two significant events in 2013 underscored the nexus of marriage and taxes that make it possible for many couples to radically simplify their estate planning. ...more

No Good Deed Goes Untaxed – The IRS May Recharacterize Loans As Gifts

Entrepreneurs in Miami and elsewhere are familiar with making and receiving loans as commonplace tools in the management of their businesses. One need look no further than the growth of Miami’s skyline through debt-financed...more

Sale For Annuity Results In §2036 Inclusion

In a recent Tax Court case, a decedent had sold properties to trusts in exchange for fixed annuity payments. The decedent died during the term of the annuities, and the IRS sought to include the value of the transferred...more

Wealth Management Update - November 2013

Federal Exclusion from Gift, Estate and Generation-Skipping Transfer Taxes Increases to $5,340,000 in 2014 - In Revenue Ruling 2013-35, the IRS announced certain inflation adjustments to tax exemptions and deductions....more

Late Payment Of Interest Voids Code §6166 Deferral Of Estate Tax Arrangement

Code §6166 can be a lifesaver for estates with large business assets. The provision will allow qualifying estates to defer payment of estate taxes on their business interests, and then pay off the tax liability over a 10 year...more

Same-Sex Marriages Are Now Recognized for All Federal Tax Purposes

The Internal Revenue Service has issued a ruling [Revenue Ruling 2013-72, August 29, 2013] announcing that same-sex couples legally married in a state that recognized the marriage will be treated as married for all federal...more

Estate Planning Opportunities Arising from Recent Revenue Ruling Concerning Marriages of Same-Sex Couples

Revenue Ruling 2013-17 - On August 29, 2013, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (IRS) issued Revenue Ruling 2013-17 (the “Ruling”) holding that, for purposes of...more

The Supreme Court's DOMA Decision Raises More Questions Than It Answers

With the Supreme Court's decision on the constitutionality of part of the Defense of Marriage Act, P.L. 104-199 (DOMA), Edith Windsor, the plaintiff, joins the likes of Beulah Crane (Crane, 331 U.S 1 (1947)), Mary Archer...more

IRS Rejects SCIN Estate Tax Exclusion

The IRS office of Chief Counsel addressed a SCIN transaction, and concluded that the value of the note was includible in the gross estate of a decedent....more

IRA Beneficiary Suffers Transferee Estate Tax Liability 12 Years After Form 706 Filed

Notwithstanding failing to assess estate tax against an IRA beneficiary wihin the Code §6901 four year transferee statute of limitations, in U.S. v. Maureen G. Mangiardi et al, the IRS was permitted to collect estate taxes...more

Are U.S. Beneficiaries of a Foreign Estate Subject to Taxes?

When your father came to California many years ago, he left most of his family behind in Tokyo. However, you’ve gone back to Japan a number of times to visit and you developed a very close bond with your aunt. After receiving...more

How Does DOMA Ruling Affect Your Estate and Tax Planning?

The Supreme Court’s decision in Windsor v. U.S. has effectively struck down Section 3 of the Defense of Marriage Act, also known as DOMA, retroactively. Here are some tax advantages now available to married same-sex...more

Friends and Relatives in Foreign Countries? They Can Still Be Part of Your Estate Plan.

The world continues to shrink as advances in technology fuel faster communication and travel to the far reaches of the globe. As a result, people are on the move now more than ever before. No longer is a move from San...more

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