News Analysis has published an article by Lee A. Sheppard, a contributor of Tax Analysts. The article discusses foreign bank account reporting and legislation connected to tax havens under consideration in Congress. See Lee A. Sheppard, "Tax Haven Apples and Oranges," 2009 TNT 123-2...
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Tax Notes has published the comments of Martin Scheckner and Marcell Hetenyi, Certified Public Accountants of Scheckner & Hetenyi. They make several suggestions in their comments, including the availability of an electronic filing option. See Martin Scheckner and Marcell Hetenyi, Tax Notes Correspondence:...
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Tax Notes has published an article by Kristen A. Parillo, a contributor of Tax Analysts. The article reports that an IRS official has explained that U.S. investors in offshore hedge funds and private equity funds must file a foreign bank...
In PLR 200926021, the Internal Revenue Service ruled that an estate would be granted an extension to make an election under reg. section 26.2652-2(c) to treat a marital trust as two separate trusts and to make a reverse qualified terminable interest property election under...
According to TG-177, the U.S. Department of the Treasury has announced that it has concluded negotiations with Switzerland that will make changes to the U.S.-Switzerland income tax treaty to permit increased tax information exchange in order to enforce U.S. tax laws...
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H.R. 2920, the Statutory Pay-As-You-Go Act of 2009, introduced into the House of Representatives by House Majority Leader Steny Hoyer (D-Md.), would reinstitute and update the "pay as you go" restrictions on mandatory spending, requiring offsets and mandatory cuts to...
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Revenue Ruling 2009-20 provides various prescribed rates for federal income taxpurposes for July 2009 including the applicable federal interest rates, the adjusted applicable federal interest rates, the adjusted federal long-term rate, the adjusted federal long-term tax-exempt rate. These rates are determined...
In PLR 200925008, the Internal Revenue Service ruled that an estate would be granted an extension to make an election under section 2652 to treat a marital as two trusts for generation-skipping tax exemption purposes.Posted by Gary Robillard, Associate Editor, Wealth...
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In PLR 200925028, the Internal Revenue Service ruled that a couple would be granted an extension to allocate their available generation-skipping tax exemption to a transfer to a trust.Posted by Gary Robillard, Associate Editor, Wealth Strategies Journal....
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In PLR 200925018, the Internal Revenue Service ruled that estate executors would be granted an extension to allocate the decedent's available generation-skipping tax exemption to a transfer to a trust.Posted by Gary Robillard, Associate Editor, Wealth Strategies Journal....
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In PLR 200925015, the Internal Revenue Service ruled that estate executors would be granted an extension to allocate the decedent's generation-skipping tax exemption to a transfer to a trust.Posted by Gary Robillard, Associate Editor, Wealth Strategies Journal....
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In PLR 200925032, the Internal Revenue Service ruled that the income of a trust created by a state to help pay for retired state employees' medical benefits can be excluded from gross income under section 115(1) because the income stems...
In PLR 200925003, the Internal Revenue Service ruled that payments on premiums by a trust and a partnership within a split-life insurance agreement do not constitute income to, or gifts by, the grantor and that any proceeds from the policy...
In Announcement 2009-52 (2009-25 IRB 1106), the IRS corrects temporary and final regulations that make changes to the actuarial tables regarding the valuing of annuities, interests for life or term of years, and remainder or reversionary interests. See also "IRS Corrects Temporary, Final...
In Announcement 2009-50 (2009-25 IRB 1105), the IRS corrects proposed regulations (REG 119532-08, 2009-20 I.R.B. 1017) that help explain which portion of a trust can be included in a deceased grantor's estate if the grantor has reserved a graduated retained interest...
The Heritage Foundation has published a web memo titled "The Death Tax: Another Obama Tax Hike Target" by Curtis S. Dubay. In his article, Dubay proposed that instead of raising the estate tax to fund President Obama's health care plan, Congress should repeal...
Tax Notes has published an article by Sam Goldfarb, writer for Tax Analysts. The article discusses House Democrats' attempts at giving the White House the authority to reduce mandatory spending programs and the possible impact this could have on estate...
According to IR-2009-60, the IRS is offering a special tax break on new car purchases in states with no state sales tax. The deduction will vary depending on the vehicle's sales price or as a per unit fee.Posted by Min Young...
The IRS will be hosting a webinar on June 17 titled "IRS Disaster and Emergency Relief," available at 10:00 AM, 1:00 PM and 4:00 PM EST. The June 17 webinar also offers one CPE credit for those who are eligible....
Steve Akers, Associate Fiduciary Counsel, Bessemer Trust, provides the following summary of Estate of Miller v. Commissioner, T.C. Memo. 2009-119.Taxpayer Section 2036 Partial Victory For Marketable Securities FLP; Purpose of Providing Active Management of Portfolio Satisfied Bona Fide Sale Exception...
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