Estate allowed deduction for theft loss suffered by an LLC in which it held an interest
The Tax Court finds a sufficient nexus between the Ponzi scheme theft loss suffered by an LLC and the value of the estate's interest in the LLC.
Taxation of Estates & Trusts
Proposed regulations would affect estate valuation discounts
The IRS aims to close a 'loophole' of lapsing rights and restrictions in transfers of family-owned businesses.
IRS issues 2017 inflation adjustments for many tax provisions
The IRS issued its annual revenue procedure containing inflation-adjusted amounts for the 2017 tax year, affecting over 50 Code provisions, as well as the new tax rate tables for individuals and estates and trusts.
Guidance allows QTIP election where executor elects portability
The IRS removed a prohibition on making a qualified terminable interest property (QTIP) election when the election would have been null and void because the estate had a zero estate tax liability.
Estate basis consistency and reporting: What practitioners need to know
The new law imposes a potentially elaborate reporting regime for values of estate property and ominous consequences for failures.
The importance of appraisals when gifting art
Charitable deductions stand a much better chance of being upheld when taxpayers closely follow the qualified appraiser rules.
Estates have until June 30 to file estate basis form
The IRS announced one last postponement in the due date for filing under rules requiring reporting of the value of an estate’s assets to the IRS and beneficiaries.
What to do when a client wants to give an LLC or limited partnership unit to charity
Many charitable organizations will not accept a gift of an LLC or limited partnership units because the entity’s business is not part of their charitable mission.
Estate basis consistency reporting rules are proposed
The regulations reiterate the delayed reporting deadline of March 31, 2016.
Family stock transfer 44 years ago was a taxable gift
Sumner Redstone’s 1972 transfer to children’s trusts, unlike his brother’s, was voluntary and nonbusiness-related.
Trusts prevail in transferee liability case
State law theories of liability were not proved, the Tax Court holds.
Due date for estate basis reporting postponed once again
The IRS further postponed the due date for the new reporting requirement, under which estates must report the value of estate assets to the IRS and to beneficiaries.
Redstone family stock transfer was not a taxable gift
The 1972 transfer was in the ordinary course of business and for full and adequate consideration, the Tax Court holds.
Tax Court allows discount for assumption of estate taxes
A net gift calculation is accepted under the willing buyer/seller test.
New tax on expatriates’ gifts and bequests gets prop. regs.
The highest gift or estate tax rate applies after the gift tax annual exclusion amount; the marital deduction and QTIPs are among the possible exclusions.
Tax Court determines value of remainder interest of a NIMCRUT
The remainder interest must be calculated assuming annual distribution amounts equal to the greater of 5% or the fixed percentage stated in the trust instrument.
Converting from C to S corp. may be costlier than you think
Gift or estate valuation of interests may be significantly higher, incurring more tax.
IRS issues 2016 inflation adjustments and tax tables
The IRS issued the annual inflation adjustments for 2016 for more than 50 tax provisions as well as the 2016 tax rate tables for individuals and estates and trusts.
Proposed rules govern taxation of gifts and bequests from covered expatriates
Proposed regulations under Sec. 2801 would impose a transfer tax on gifts or bequests from covered expatriates made on or after June 17, 2008.
IRS issues final portability rules for estate tax exemptions
No short-form option is provided; regulatory time extension is allowed only for estates valued below the filing threshold.
