The IRS issued final regulations increasing the cost of an estate tax closing letter to $76 from $56, adopting without change proposed regulations issued in June.
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TOPICS / TAX
Taxation of estates & trusts
IRS proposes increase in cost of estate tax closing letter
Proposed regulations issued Monday would raise the cost of the letter to $76, from the $56 set in 2025.
Avoiding a big tax bill on inherited IRAs
The 10-year drawdown rule can trigger hefty taxes for heirs. Learn how smart planning can help.
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.
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.
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.”
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.
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.
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.
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.
Motion to quash writ of execution denied
Estate tax levy on antique cello survives executor’s claim that a trust owned the instrument.
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.
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.
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.
Late special-use valuation permitted
A district court allows the election for qualified real property on an estate return filed more than five years late.
Checks written before death are includible in decedent’s estate
The Tax Court follows state law in determining whether delivered but unpaid checks were completed gifts.
Estates can now request late portability election relief for 5 years
The IRS extended to five years the period under which a taxpayer can use a simplified method (in lieu of a letter ruling request) to obtain an extension of time to make a portability election.
Regs. proposed for present value of estate deductions
Administrative expenses and claims against estates allowable under Sec. 2053 beyond a three-year grace period would be discounted for current deduction, under proposed rules issued by the IRS.
Value of split-dollar arrangement is not its cash surrender value
In the latest IRS challenge to an intergenerational split-dollar arrangement, the taxpayer prevails.
No step-up in basis for private foundation’s assets
A PMTA disagrees with a prior letter ruling.
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