The Presumption of Innocence Podcast: Episode 21 - Conservation Easement Donations: Tax Shelter or Charitable Contribution Deduction?
Jones Day Presents: Strategies for Dealing with IRS Appeals: When Exam Attends the Appeals Conference
Jones Day Presents: Strategies for Dealing with the IRS: Going to Court
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Appeals Office
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
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
On December 12, 2022, the Minnesota Tax Court released an opinion in Estate of Anderson v. Commissioner of Revenue addressing the constitutionality of Minnesota’s estate tax structure as applied to an estate that consisted...more
Tax Litigation: The Week of February 28, 2022, through March 4, 2022 - Shaddix v. Comm’r | TC Memo. 2022-11 | February 28, 2022 | Lauber, J. | Dkt No. 12683-20L - Estate of Kazmi v. Comm’r, T.C. Memo. 2022-13| March 1,...more
February 2022 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split-Interest Charitable Trusts....more
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
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
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
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
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
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
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
November 2019 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split-Interest Charitable Trusts - The November Section 7520 rate for use with estate planning techniques such as CRTs,...more
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
On August 21, 2017, the Tax Court issued its opinion in two companion cases Benyamin Avrahami and Orna Avrahami v. Commissioner, and Feedback Insurance Company, Ltd. v. Commissioner, 149 T.C. No. 7, holding against the...more
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
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
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
Looking Beyond the Morrissette Decision and Around the Corner for Inter-Generational Split Dollar - Overview - I have had the opportunity throughout my career to know top life insurance agents as well as several top...more
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
Lifetime giving is a smart strategy to reduce a taxable estate, but the gift tax rate of 40% is steep. If one has used up his or her $5.43 million gift and estate tax exemption and would like to potentially reduce his or her...more
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