News & Analysis as of

Landmark US Supreme Court Decision May Extend US Tax Benefits to UK Civil Partners

On Wednesday, 26 June 2013, the US Supreme Court ruled that Section 3 of the Defense of Marriage Act (“DOMA”), which limits the definition of “marriage” to “a legal union between one man and one woman as husband and wife” and...more

New Tax Act Provides Long-Awaited Clarity and Certainty on Estate, Gift and Generation-Skipping Transfer Taxes, and Income Tax...

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

It’s Official – Exclusion Amount Confirmed At $5.25 Million

For federal estate and gift tax purposes. This was the figure projected by some tax service publications – now the IRS concurs....more

Late Gift Filing Could Not Use Unified Credit

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

Gifting? Make Sure You Include Your Prior Gifts

Many people are making gifts before the end of 2012 to take advantage of the disappearing $5.12M gift tax exemption ($10.24M for a married couple). When figuring out the maximum amount that can be given, gifts from prior...more

IRS May Challenge Future Formula Gift Clauses

In October, the IRS dropped its appeal of the Tax Court decision in Wandry v. Commissioner, T.C. Memo 2012-88. That does not mean the IRS accepts the holding of the Court. In fact, the IRS just announced that it will not do...more

IRS Reaffirms It Will Challenge Formula Gifts

With December 31st approaching quickly and the large $5,120,000 gift tax exemption disappearing, many clients are scrambling to make year-end gifts. Our advice has been to make every effort to get appraisals by the end of...more

Should you set up an old-fashioned family limited partnership?

The family limited partnership was a fairly unusual way for wealthy families to manage their real estate and various financial accounts. But this year it is coming back into fashion. Why? The reason this esoteric and...more

2012 Year-End Income, Estate & Gift Tax Planning

With 2012 drawing to a close, many Americans may see the end of “Bush-era” income tax cuts as well as significant estate and gift tax reductions, the loss of which will dramatically affect their tax liability in 2013 and...more

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