News & Analysis as of

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.

IRS Issues Guidance Regarding Estate Tax Lien Discharge Process

by Charles (Chuck) Rubin on

When an individual dies, an estate tax lien attaches automatically to all of the property included in the gross estate. It arises prior to tax assessment, and is not recorded....more

For High-Income and International Taxpayers: Defensive Tax Planning

The Importance of Defensive Tax Planning - IRS audit criteria target high-income taxpayers, especially those with reported foreign income or foreign financial assets. Targeted high income taxpayers include...more

New Reporting Regime: Estates Who Have to File Federal Estate Tax Returns Need to be Aware of New Basis Consistency Law

by Bowditch & Dewey on

On July 31, 2015, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 introduced new tax law that affects executors who are required to file a federal estate tax return and beneficiaries...more

Tax Tips

Internal Revenue Service Temporarily Holding Off on Issuing New Regulations - The Internal Revenue Service is temporarily holding off on issuing new rules while evaluating the impact of executive orders from President...more

Court Orders Administrator To Elect Portability

by Bryan Cave on

When the IRS enacted the portability election provisions in 2011, which allowed estates of married taxpayers to pass along the unused part of their estate and gift tax exclusion amount to their surviving spouse, it remarked...more

A “Thriller” in Tax Court: The Estate of Michael Jackson and IRS Dispute Valuation of Pop Star’s Image

by Bowditch & Dewey on

How much were the late King of Pop’s name and image worth when he died? His estate put the figure at $2,105 but the IRS believes the value is at least $434 million. That’s a huge discrepancy and with penalties and interest...more

Copying is Best in the ING World

by Bryan Cave on

Not only is strict adherence to the structure set out in prior favorable rulings best, it is essential when it comes to obtaining a favorable ING ruling. The provisions in the trust document need to carve a very fine line...more

IRS Limiting GST Private Letter Rulings and Presubmission Conferences

by Charles (Chuck) Rubin on

At a recent Federal Bar Association Tax Law Conference, an IRS Chief Counsel branch chief advised that due to budget cuts: a. The IRS has temporarily suspended issuing private letter rulings regarding modifications to...more

The Future Of Proposed IRS § 2704 Modifications Is Uncertain

Proposed changes to Internal Revenue Code (IRC) § 2704, which would impact the valuation of transfers of family business interests at death, come at an interesting time politically given the Trump Administration’s desire to...more

State and Federal Tax Law Developments Affect Same-Sex Couples and MA Residents with Out-of-State Real Estate

by Goodwin on

Recent changes in state and federal tax laws impact same-sex couples and any Massachusetts residents who own real estate in another state. Clients who may be affected by these changes should act soon to protect the...more

No Automatic Closing Letter, But Wait – There Are Alternatives

by Bryan Cave on

IRS Notice 2017-12 - The Service issued FAQs in June of 2015 to let practitioners know that they were no longer routinely issuing closing letters. The Service instructed practitioners that they would now have to request...more

Michael Jackson Estate Tax Case Moving Forward

by Charles (Chuck) Rubin on

Most estate tax practitioners will tell you estate tax it is all about valuation when assets are other than cash and marketable securities. The estate tax case of the Michael Jackson estate is an ideal demonstration. Tax...more

Client Alert: Estate and Gift Tax Limits Announced for 2017

by Fraser Trebilcock on

The IRS has issued the estate and gift tax limits for 2017 (Rev. Proc. 2016-55). For an estate of a person dying in 2017, the basic exclusion amount is $5,490,000 for determining the credit against federal estate tax. This...more

Wealth Management Update - February 2017

by Proskauer Rose LLP on

February Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The February § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more

A Substitute for Estate Tax Closing Letters

by Pessin Katz Law, P.A. on

In Notice 2017-12 (the “Notice”) the IRS announced that an “account transcript” from the agency can substitute for an Estate Tax Closing Letter (“ETCL”)....more

January Tax Tidbits

Tax Tips for January 2017 are listed below. Rev Rul 2017-02, 2017-3 IRB January 2017 Rates: ..Section 7520 Rate: 2.4% ..Annual Short Term AFR (0-3 years): 0.96% ..Annual Mid Term AFR (3-9 years):...more

IRS Permits Trust Division Without Adverse Federal Tax Consequences

by Charles (Chuck) Rubin on

In Private Letter Rulings 201702005 and 201702006, the IRS favorably ruled on federal tax consequences of a proposed trust division. But for a minor change in facts, the two rulings are identical, so we will focus only on...more

Statute of Limitations and Collections Process Against Executrix and Agent for Estate Tax Deficiency

United States v. Holmes - 2016 WL 4363398 (SD Tex. Aug. 16, 2016) Summary - Summary judgment was sought by both the taxpayers and the Government for an estate tax liability. The taxpayers contended that the...more

Federal Gift, Estate Tax and Generation-Skipping Transfer Tax Exemptions & the Gift Tax Annual Exclusion Amount Are Subject to...

by Dickinson Wright on

The exemptions were increased in 2017 from $5,450,000 to $5,490,000, and the annual exclusion remains the same at $14,000 per donee. These rules mean the following...more

Federal Regulatory Freeze

by Pierce Atwood LLP on

Please see chart below....more

Change is Coming: A Look at Trump and Republican Tax Proposals

by Barley Snyder on

Tax reform is coming, and you better be ready. Regardless of how you voted in November, the United States will have a new president Friday and the Republican Party will be in control of both houses of Congress....more

A Reprieve from Proposed Regulations Related to Valuation of Family Businesses?

In December, we posted a blog discussing a much anticipated hearing held on the Treasury Department’s issuance of proposed regulations under Section 2704 of the Internal Revenue Code (sometimes referred to as the 2704...more

IRS Formalizes Transcripts as Substitute for Estate Tax Closing Letters

by Charles (Chuck) Rubin on

In 2005, I discussed how the IRS had posted information on its website that an account transcript notation bearing transaction code “421” could be used to determine that the IRS had concluded its review of a filed estate tax...more

Estate Administrative Update: IRS Notice Confirms Account Transcripts May Serve as Estate Tax Closing Letter

by Williams Mullen on

Recently, the IRS issued Notice 2017-12, providing further guidance on ways to confirm that the IRS has closed its examination of an estate tax return. Notice 2017-12 officially confirms what the IRS website has said for...more

Treasury Department Unofficial Statements on Proposed Section 2704 Regulations

by Charles (Chuck) Rubin on

There is a lot of uncertainty whether the Section 2704 proposed regulations will ever be finalized, either due to policy to be set by President-elect Trump, and/or Congressional efforts to block those regulations....more

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