On August 14, the IRS issued Notice 2007-73, which identifies as transactions of interest for purposes of Treas. Reg. § 1.6011-4(b)(6) and IRC §§ 6111 and 6112 transactions that involve "toggling" grantor trust transactions. "Transactions of interest" is a new...
August 2007 Archives
On August 14, the IRS issued IRS Notice 2007-72, which identifies as transactions of interest for purposes of Treas. Reg. § 1.6011-4(b)(6) and IRC §§ 6111 and 6112 transactions that involve contributions of a successor member interest in an LLC...
Tax Notes has published an article by Richard A. Dees, of McDermott Will & Emery, which examines the Strangi decisions and other cases that relate to Section 2036. According to Tax Notes: In part one of a two-part article, the...
The BNA Daily Tax Report ("DTR") summarized an ABA Annual Meeting Panel discussion, entitled "Patenting Tax-Related Inventions: What's All the Fuss About?", at 156 DTR G-5 (Aug. 14, 2007). The panelists included Professor Ellen P. Aprill, Associate Dean for Academic...
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The US District Court for the Northern Districct of California, in Stone v. United States, 2007 U.S. Dist. LEXIS 58611 (N.D. Cal. Aug. 10, 2007), held that the appropriate discount for fractional interests in art work was five percent rather...
The BNA Daily Tax Report ("DTR") reports, in a summary of a panel discussion at the ABA annual meeting, that the IRS is broadening and intensifying its efforts to obtain information on offshore financial accounts owned by US taxpayers. See...
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The August 20, 2007 issue of Business Week contains an interesting article, "School Gifts That Skip Uncle Sam: Well-off relatives can set up a HEET to pay tuition for one generation or many." This is the most current of several...
The following articles from the May/June 2007 issue of the Wealth Strategies Journal are available for download: Family Incentive Trusts: Dynamic New Approach Employing Trust Distributions to Communicate Family Values and to Promote Productivity and Performance in Beneficiaries by James...