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Termination Internal Revenue Code (IRC) Tax Court

ArentFox Schiff

A Tale of Two Recent QTIP Trust Termination Cases — Anenberg and McDougall

ArentFox Schiff on

Through the years, the US Tax Court has provided significant clarification on the gift tax consequences of terminating qualified terminable interest property (QTIP) trusts. Two new cases in 2024, Estate of Sally J. Anenberg...more

Cadwalader, Wickersham & Taft LLP

Getting Technical with Partnership Termination Rule

The Tax Court recently ruled that a new partnership (“New Shoals”) that is deemed to form on a technical termination may use a taxable year that starts on the date of the termination of the old partnership (“Old Shoals”),...more

Mintz

Tax Court Provides Color on “For Cause” Termination Under Code Section 83

Mintz on

On December 16, 2013, the Tax Court decided a case that sheds important light on the meaning of the term “substantial risk of forfeiture” under section 83 of the Internal Revenue Code of 1986, as amended (the “Code”). The...more

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