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IRS’s December Surprise: Shifting Sands in Estate Planning with Trust Tax Reimbursement Revisions

On the last workday of the year, December 29, 2023, the IRS issued a Chief Counsel Memorandum adding a wrinkle to one of the most estate planning techniques – to give assets away for estate tax purposes but not income tax...more

If It's Too Good To Be True...The Latest Guidelines from the IRS

There are a lot of very smart tax attorneys out there who are trying to figure out something new, and yet there’s very little innovation.  Almost all techniques that we use are incremental variations of an older technique...more

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