News & Analysis as of

Trusts Tax Court

Rivkin Radler LLP

Transferee Liability for Estate Tax: The Downside of Being a Beneficiary

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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

Freeman Law

Tax Court in Brief | Estate of Kalikow v. Comm’r | Estate Tax Taxation and Deductions and QTIP Trust

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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

Rivkin Radler LLP

Tax Changes In The Offing? “Close Scrutiny” Of Business Owners’ Economic Benefits Remains A Constant

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I Read the News Today- Much of today’s news is dominated by the future of the Administration’s broadly defined infrastructure plan. Discussions among “those in the know” inevitably turn into debates over the wisdom of...more

Farrell Fritz, P.C.

The Threat Of Higher Taxes, & The Sirens’ Song Of Tax-Saving Schemes

Farrell Fritz, P.C. on

What a Mess- A “perfect storm” may be defined as a critical state of affairs arising from the convergence of a number of negative factors, often after the unexpected introduction of some catalytic event. The situation...more

Katten Muchin Rosenman LLP

2017 Year-End Estate Planning Advisory

The fourth quarter of 2017 concludes a unique year in the planning arena. With the new administration and a Republican-led Congress in power, both taxpayers and tax professionals have kept a close eye on the potential for tax...more

Katten Muchin Rosenman LLP

2016 Year-End Estate Planning Advisory

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

Coblentz Patch Duffy & Bass

Transferee Liability: The [Unlikely] Situation that your Nonprofit Receives a Charitable Gift with Expensive Tax Strings Attached

The case of Salus Mundi Foundation et al v. Commissioner - On August 15, 2016, the Tax Court decided in Salus Mundi Foundation et al v. Commissioner, T.C. Memo. 2016-154, that two foundations were liable as transferees...more

McGuireWoods LLP

Parties Settle Closely Watched Tax Court Cases Involving Defined Value Clause

McGuireWoods LLP on

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

Proskauer Rose LLP

Wealth Management Update - August 2015

Proskauer Rose LLP on

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

Proskauer Rose LLP

Wealth Management Update - June 2015

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...more

BakerHostetler

Still Waiting For Guidance on Material Participation

BakerHostetler on

In March 2014, I commented on the US Tax Court decision in the Frank Aragona Trust case. In that case, the tax court disagreed with the Internal Revenue Service’s arguments that a trust was incapable of providing “personal...more

Troutman Pepper

In Frank Aragona Trust, Tax Court Holds that Trustees’ Activities as Employees Count for Purposes of Material Participation Under...

Troutman Pepper on

The issue of whether a trust has passive or non-passive income from its investment in a pass-through entity has taken on increased importance in light of the tax imposed on net investment income under Code Section 1411 of the...more

Shumaker, Loop & Kendrick, LLP

"The Estate Planner" – July/August 2014

In this issue: - Net Gain For Taxpayers – Tax Court Approves Net Gift Strategy - Estate Planning For The Young And Affluent – How To Hedge Your Bets - Wealth Preserver – Use An ILIT To Shield Life...more

Shumaker, Loop & Kendrick, LLP

"The Estate Planner" – May/June 2014

In this issue: - Valuing LLC Interests: How To Lose In Tax Court - Should You Keep Your Trust A Secret? - Effort – A “Stretch IRA” Can Maximize Your IRA’s Benefits - Estate Planning Red Flag – You...more

Levenfeld Pearlstein, LLC

Frank Aragona Trust: A Taxpayer Win

In a case of first impression, Frank Aragona Trust v. Commissioner, 142 T.C. No. 9 (Mar. 27, 2014), the Tax Court held that a trust could materially participate in a trade or business based upon the activities of the...more

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