Taxation of estates & trusts

TOPICS / TAX

December 1, 2025

Estate’s portability election held invalid

The taxpayer’s predeceased spouse’s estate failed to timely file an estate return and did not qualify for the safe harbor in Rev. Proc. 2017-34, so its portability election was invalid, the Tax Court held.

August 29, 2025

Guidance on research or experimental expenditures under H.R. 1 issued

The revenue procedure advises taxpayers how to make various elections, file amended returns, and change accounting methods as provided under Section 70302 of the new law.

June 19, 2025

Tax provisions of Senate Finance’s version of the budget bill

The 549-page text calls for making many provisions of the Tax Cuts and Jobs Act permanent. The committee says that the SALT cap amount is “the subject of continuing negotiations.”

May 16, 2025

IRS reduces user fee for estate tax closing letters

The receipt of an estate tax closing letter generally indicates that the estate tax return’s IRS examination is closed. Final and proposed regulations lowered the fee by $11.

September 16, 2024

Final regs. issued on consistent-basis and basis-reporting rules

The IRS issued guidance for recipients of property from decedents on the basis-consistency requirement and for executors and others on basis-reporting requirements.

June 7, 2024

Supreme Court: Insurance proceeds increase corporation’s estate tax value

In a unanimous decision, the Supreme Court holds that life insurance proceeds a corporation receives to fund a share redemption agreement increases the corporation’s estate tax value.

April 3, 2024

Supreme Court to decide estate tax impact of life insurance in closely held businesses

This term, the Supreme Court will answer the questions regarding the estate tax treatment of life insurance proceeds received by a closely held business and its shareholder redemption obligations. It heard oral arguments last week.

October 1, 2023

Motion to quash writ of execution denied

Estate tax levy on antique cello survives executor’s claim that a trust owned the instrument.

September 1, 2023

IRS is time-barred from assessing gift tax

The Tax Court holds the taxpayer substantially complied with adequate-disclosure requirements via returns and documents submitted with an OVDP offer.

July 1, 2023

Estate’s claimed deductions recharacterized as gifts or bequests

Payments purportedly for care and companionship were not evidenced as bona fide consideration or compensation as claims against the estate, the Tax Court holds.

March 31, 2023

No basis step-up for grantor trust assets if not in grantor’s estate

In a revenue ruling issued Wednesday, the IRS confirms that the step-up in basis under Sec. 1014(a) does not apply to the assets held by an irrevocable grantor trust when the grantor dies if the grantor’s gross estate does not include the assets of the irrevocable trust.

March 1, 2023