News & Analysis as of

Internal Revenue Code (IRC) Trusts Tax Liability

Rivkin Radler LLP

“Hey Mom, Can I Have A Few Bucks?” Is It A Loan? A Gift? A Little of Each?

Rivkin Radler LLP on

A parent will sometimes transfer money to a child to enable the child to make an investment that the child could not otherwise make on their own. For example, the child may have identified an attractive business opportunity...more

Gray Reed

Understanding IRS Private Letter Ruling 202504006: Crucial Takeaways for Tax Planning

Gray Reed on

The Internal Revenue Service (IRS) recently issued Private Letter Ruling (PLR) 202504006, addressing several important estate and gift tax questions related to the division of a marital trust and the subsequent disclaimer of...more

Kohrman Jackson & Krantz LLP

Act Now or Pay Later? Will Congress Extend the Higher Estate Tax Exemption Before 2026?

As we approach the end of the first quarter of 2025, estate planners and their clients are closely monitoring developments in Washington, D.C. The scheduled sunset of the increased estate and gift tax exemption is now less...more

Adler Pollock & Sheehan P.C.

How an HSA Can Benefit Your Estate Plan

A Health Savings Account (HSA) can positively affect your estate plan. How? In addition to serving as a viable option to reduce health care costs, an HSA’s funds grow on a tax-deferred basis. In fact, an HSA is similar to a...more

Allen Barron, Inc.

A Foreign Trust Creates Complex IRS Reporting Requirements

Allen Barron, Inc. on

The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more

Rivkin Radler LLP

Will the Federal Estate and Gift Tax Exemption Be Reduced in 2026?

Rivkin Radler LLP on

The federal estate and gift tax exemption changes from year to year. The current combined federal estate and gift tax exemption amount of $13.99 million per person ($27.98 million per married couple) is scheduled to “sunset”...more

Rivkin Radler LLP

Expiring Federal Transfer Tax Benefits – Nothing is Certain or Lasts Forever

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Just a few weeks ago, many individual taxpayers, driven by what they viewed as the relatively imminent expiration of the enhanced federal transfer tax exemptions, sought advice on how to leverage their remaining exemption and...more

Vorys, Sater, Seymour and Pease LLP

The Importance of Actively Monitoring S Corporation Compliance

Many banks have elected to be “S Corporations” for tax purposes. This status can provide significant tax benefits to the bank’s shareholders, but it also comes with several ongoing technical requirements. Failure to satisfy...more

Jaburg Wilk

Exclusions, Exemptions, Estate Tax – What to Know in 2025

Jaburg Wilk on

As we enter 2025, it’s important to stay informed about the current federal estate and gift tax laws, including annual exclusion limits and significant changes anticipated by the end of this year. Annual Exclusion Amount- ...more

Rivkin Radler LLP

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

Rivkin Radler LLP on

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

Gray Reed

A Horse, a Horse, My Kingdom for a Horse! Lack of Proper Documentation Dooms IRS Disputes

Gray Reed on

In real life (and especially, it seems, in tax law) it is more like to be the lack of a timely piece of paper that causes the taxpayer to lose. In the course of administering a trust, it sometimes happens that mistakes...more

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

Foster Garvey PC on

...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more

McDermott Will & Emery

Weekly IRS Roundup September 27 – October 1, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 27, 2021 – October 1, 2021... September 28, 2021: The IRS released a revenue...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

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