News & Analysis as of September 19, 2024

Tax Court

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Estate Planning is a process where individuals prepare or plan for the settlement of their personal affairs in the event of incapacitation or death. Estate plans typically include provisions relating to the disposition of assets, guardianship of minor children, and appointment of representatives to make medical and financial decisions. Effective estate planning can decrease tax liability and facilitate the probate process. less -

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

Rivkin Radler LLP on 8/11/2023

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

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

Freeman Law on 3/13/2023

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 Court in Brief | Estate of Levine v. Commissioner | Split-Dollar Life Insurance and Estate Planning

Freeman Law on 3/7/2022

Tax Trial of the Century…

Smith Gambrell Russell on 6/7/2021

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

How Dealings Between Related Parties Doomed A Captive Insurer

Farrell Fritz, P.C. on 3/17/2021

Insurance: What is it? How does it work? Assume that Acme Co is paying premiums for commercial insurance coverage to protect itself from economic losses that may arise out of various events. These premiums are deductible...more

Prince’s Controversy: A Cautionary Tale of Improper Estate Planning

Bowditch & Dewey on 2/10/2021

The controversy surrounding the wealth left behind by Prince after his sudden death in 2016 is heating up again after the IRS determined that Prince’s estate is worth approximately $163 million, or twice what his estate...more

Intra-Family Loan: A Gift Alternative In Turbulent Times?

Farrell Fritz, P.C. on 9/28/2020

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

Wealth Management Update - July 2020

Proskauer Rose LLP on 7/2/2020

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

Wealth Management Update - March 2020

Proskauer Rose LLP on 3/10/2020

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

Wealth Management Update - December 2019

Proskauer Rose LLP on 12/3/2019

December 2019 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split-Interest Charitable Trusts - The December Section 7520 rate for use with estate planning techniques such as CRTs,...more

Cahill Case Sheds Light on Tax Court’s View of Intergenerational Split Dollar Agreements

Williams Mullen on 9/25/2018

On June 18, 2018, the Tax Court issued a memorandum denying a motion for partial summary judgment filed by the Estate of Richard Cahill (T.C. Memo 2018-84). It was the second time in two years that the Tax Court had addressed...more

2016 Year-End Estate Planning Advisory

Katten Muchin Rosenman LLP on 11/22/2016

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

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

Coblentz Patch Duffy & Bass on 10/12/2016

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

Double Down! - Inter-Generational Split Dollar Throws Sand in the Face of the IRS Again

Gerald Nowotny - Law Office of Gerald R.... on 8/1/2016

Recently I wrote an article on JD Supra called Split to Be Tied (May 4, 2016) regarding the Tax Court decision in Estate of Morrissette, (Estate of Clara M. Morrissette v. Commissioner, 146 T.C. No. 11 (April 13, 2016)). Once...more

Parties Settle Closely Watched Tax Court Cases Involving Defined Value Clause

McGuireWoods LLP on 4/4/2016

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

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