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Still Waiting For Guidance on Material Participation

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

U.S.Tax Court Decision May Allieviate The 3.8% Net Investment Income Tax Burden For Many Trusts

Because trusts are subject to the 3.8% Net Investment Income Tax at a very low income level, $12,150 for 2014, trustees of trusts owning interests in operating entities have been considering ways to meet the material...more

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