Once Removed Episode 19: The Step-Transaction Doctrine and the Case of Smaldino
Once Removed Episode 18: The Reciprocal Trust Doctrine
Charitable Planning With Guest Stephanie Hood: Navigating Complex Rules and Traps for the Unwary
Once Removed Episode 16: Gift and Estate Tax, Inflation Adjustments for 2024
Once Removed Episode 17: Annual Gifting to Individuals: Options, Opportunities and Pitfalls
Once Removed Episode 12: SLATs and the Case of McKim vs. McKim
Once Removed Episode 11: Spousal Lifetime Access Trusts, or SLATs
Once Removed Episode 10: Trustee Removal and Case Update on Leo Kahn Revocable Trust
(A)ESOP's Fables - The Income and Estate Tax-Free ESOP
The Renoir Spelling Bee
Taking the Sting Out of Death Taxes with Dylan Metzner, Jones & Keller
RETURN TO FOREVER - What Game Shall We Play Today?
To Give or Not to Give: Considerations for Year-End Gifting
INTRODUCING MALTA SPLIT DOLLAR
THE PAPER CHASE
With a Little Help from My Friends
The Greatest Gift: Your Individual + Family Estate Plan
In a recent Tax Court decision, the court reviewed the activities of the Huffman family as it pertained to corporate dealings involving the family aviation business (Infinity Aerospace Inc. which the court refers to by its...more
Many taxpayers have art collections. However, the art collections of some high-net-worth individuals, family offices, and business taxpayers may draw the unwanted eye of the IRS. With the increased focus on auditing...more
United States v. Firestone - In United States v. Firestone, the United States (Government or U.S.) sought to enforce a judgment against Defendant Omar Firestone (Omar) for outstanding tax liabilities related to the Estate of...more
Death of a Parent- In the context of a family-owned business, it is often the case that the matriarch or patriarch of the family is also the chief executive of the business. They may have founded the business, or they may...more
Summary: Pearl B. Kalikow’s (“Pearl”) husband died in 1990. On January 4, 2006, Pearl passed away. The SK Trust (“Trust”) was created with the remainder of Pearl’s husband’s estate. On Pearl’s husband will it was instructed...more
Tax Litigation: The Week of February 28, 2022, through March 4, 2022 - Shaddix v. Comm’r | TC Memo. 2022-11 | February 28, 2022 | Lauber, J. | Dkt No. 12683-20L - Estate of Kazmi v. Comm’r, T.C. Memo. 2022-13| March 1,...more
We previously provided an overview of the time limits imposed on the Internal Revenue Service (IRS) for assessing federal tax. The general rule is that the IRS must assess tax within three years from the later of the due date...more
Tax the Rich? The President’s plan for a tax regime that would ensure the rich pay their “fair share” of the cost of implementing his programs has come one step closer to being realized . . . maybe . . . well, sort of ....more
This program is the first of Freeman Law’s multi-class course designed to prepare CPAs and Enrolled Agents for the Tax Court’s admissions examination. Participants will receive an overview of the Tax Court and will learn...more
Which does not belong: Bad, Thriller, Moonwalk, Tax Court. Actually it is not a fair question because they all have one thing in common, Michael Jackson. The last one being the Estate of Michael J. Jackson v. Commissioner...more
Two things are virtually certain in life: death and taxes. But, one more should be added to the list where the two converge—an IRS audit. Indeed, this scenario played out all too well for the “King of Pop,” Michael...more
Woe to Us? We live in strange times. The coronavirus pandemic hit the United States hard, the scientific community fears a second round later this year, and there have been wildly differing estimates over when an...more
July 2020 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intrafamily Loans and Split-Interest Charitable Trusts - The July Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more
On April 9, 2020, the IRS issued Notice 2020-23 (the “Notice”), which extends more tax deadlines to cover individuals, estates, corporations and others. The notice expands upon tax relief granted in prior IRS notices that...more
The IRS has issued a new notice answering outstanding questions about previous filing and payment deadline extension notices and adding to the list of forms and payments covered by the extension until July 15, 2020. Notice...more
March 2020 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - Important federal interest rates continue to hold relatively steady. The March Section 7520...more
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
December Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The December § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more
In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more
In March 2014, I reported on the all-out battle that was ensuing in the U.S. Tax Court between the IRS and the Estate of Michael Jackson over the value of the late pop singer’s estate. It began in 2013, when the estate...more
In Steinberg v. Commissioner, 145 T.C. No. 7 (September 16, 2015), an 89 year old donor made a $109 million taxable gift to her four daughters. The gift was made after the donor and the daughters entered into a gifting...more
The IRS and executors have settled two cases in the United States Tax Court involving members of the Woelbing family, who own Carma Laboratories, Inc., of Franklin, Wisconsin, the maker of Carmex skin care products, and a...more
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
In a recent taxpayer victory, the Tax Court found in favor of the taxpayer with respect to three hotly contested gift and estate planning issues involving family limited liability companies. The Tax Court decided the case of...more
IRS Updates Administrative Appeals Process for Cases Docketed in Tax Court - In Notice 2015-72, the Internal Revenue Service (IRS) provided a proposed revenue procedure to update Rev. Proc. 87-24, 1987-1 C.B. 720, which...more