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 Schools Taxpayers On Duty Of Consistency

by Charles (Chuck) Rubin on

Shirley died in October 1997. The estate filed an estate tax return and paid the tax indicated. The IRS subsequently audited Shirley’s estate and issued a notice of deficiency. After Tax Court proceedings, the court issued a...more

Estate Administration Update: A Simplified Procedure for the Portability Election

by Williams Mullen on

Recently, the IRS issued Revenue Procedure 2017-34 (the “Revenue Procedure”), providing a simplified process for certain estates requiring an extension of time to make a portability election under § 2010(c)(5)(A) of the...more

IRS Simplifies Ability To Obtain Late Portability Election Relief

by Cole Schotz on

On June 9, 2017, the Internal Revenue Service issued Revenue Procedure 2017-34, which is effective immediately and provides a simplified method to obtain permission for an extension of time under Reg. 301.9100-3 to file Form...more

Wealth Management Update - June 2017

by Proskauer Rose LLP on

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

Estate Tax Changes Past, Present and Future

by McGuireWoods LLP on

I. INTRODUCTION - This outline is a selective and evolving review of the history of the modern federal estate tax. It originated during the attempts to repeal the estate tax in President Clinton’s second term and...more

More on Transfer Tax Issues Post Windsor and the Legalization of Same-Sex Marriage

by Bryan Cave on

In a recent Notice, the Internal Revenue Service set forth some administrative procedures helping taxpayers recalculate gift and generation-skipping transfer tax exemption with respect to gifts and bequests made to or for the...more

Why Care About Business Valuation? Part II

by Farrell Fritz, P.C. on

Valuations figure prominently in determining the proper tax treatment of transactions – such as sales, loans, leases, and performance of services – between related taxpayers, including, for example, commonly-controlled...more

Wealth Management Update - May 2017

by Proskauer Rose LLP on

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

Estate Tax Changes Past, Present and Future

by McGuireWoods LLP on

I. INTRODUCTION - This outline is a selective and evolving review of the history of the modern federal estate tax. It originated during the attempts to repeal the estate tax in President Clinton’s second term and...more

Paying The Estate Tax

by Farrell Fritz, P.C. on

An Unreasonable Burden? One of the reasons often given in support of the elimination of the estate tax is the economic burden it imposes upon the closely-held business; specifically, the requirement that the 40% federal...more

IRS Issues Guidance For Administration of Estate Tax Lien Discharge Requests

by McNair Law Firm, P.A. on

In June of 2016, the Internal Revenue Service (IRS) changed its procedure for granting discharges of estate tax liens and implemented centralized handling of applications for discharge. Historically, Specialty Examination...more

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

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