Wealth Strategies Journal

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Month: September 2017 (page 1 of 2)

The Comments to the Uniform Voidable Transactions Act Relating to Self-Settled Spendthrift Trusts are Correct by Kenneth C. Kettering 

Kenneth C. Kettering, has made available for download his article, “The Comments to the Uniform Voidable Transactions Act Relating to Self-Settled Spendthrift Trusts are Correct,” published in Tax Management Estates, Gifts, and Trusts Journal, vol. 42, no. 5 (Sept./Oct. 2017). The Abstract is as follows:

The comments to the Uniform Voidable Transactions

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Simonelli v. Commissioner: Married Couple’s Rental Loss Deductions Denied

In Simonelli v. Commissioner, T.C. Memo 2017-188, the Tax Court resolved the following issues in the favor of the IRS:

(1) whether petitioners are entitled to deduct expenses on Schedules C, Profit or Loss From Business, attributable to a law practice that petitioner Patrick Simonelli allegedly conducted with his son … Continue reading

TIGTA Says IRS Must Improve Estate Tax Audits in September 26 Audit Report

TIGTA issued a report that says that IRS guidance, classification sheet documentation, and oversight of estate and gift tax return examinations must be improved. It’s report includes specific recommendations for improvement.

See full TIGTA Report by clicking here. 

Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.

Joint Committee on Taxation Report: Background And Selected Policy Issues On International Tax Reform

The Joint Committee on Taxation has released its publication, Background And Selected Policy Issues On International Tax Reform, summarizing the principles of international taxation.

See full publication at JCX-45-17 (September 28, 2017)

Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.

Commentary Omnibus.2017.09.25: PWC Launches Law Firm, New Wealthiest Woman in World; New FBAR Willful Failure Decision; When Sharia & US Tax Law Collide

  • PWC to Launch Law Firm.   Big Four firm PwC is launching an independent law firm in the U.S., according to published reports. The unit, which will be called ILC Legal, will be a separate entity from the firm, and will not offer advice on U.S. law, according to Law.com,
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Commentary Omnibus.2017.09.22: Dealing With Clients Wanting Discounts; 2018 Tax Rates; Estate Tax Portability; Protecting Yourself From Equifax Hack; Surviving Identity Theft; Residency Tax Planning for Noncitizens

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Fiduciary Duties in Bankruptcy and Insolvency by John A. E. Pottow 

John A.E. Pottow has made available for download a chapter, Fiduciary Duties in Bankruptcy and Insolvency, from his book, The Oxford Handbook of Fiduciary Law.  The  Abstract is as follows:

Although discussed nowhere in the U.S. Bankruptcy Code, fiduciary duties play a central role in guiding the administration of an insolvent

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Borrowing in the Shadow of Death: Another Look at Probate Lending by David Horton 

David Horton has made available for download his article, “Borrowing in the Shadow of Death: Another Look at Probate Lending,” to be published in the William & Mary Law Review, Vol. 59, 2018. The Abstract is as follows:

“Fringe” lending has long been controversial. Three decades ago, demand for subprime credit soared,

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IRS Releases Publication 3125 – The IRS Does Not Approve IRA Investments

The IRS has released Publication 3125 (rev. Sep. 2017), “The IRS Does Not Approve IRA Investments,” which warns of advertisements that falsely claim IRS endorsement of a particular investment and explains how taxpayers can protect themselves.

See Publication 3125 by clicking here. 

Posted by Lewis J. Saret, Co-General Editor, … Continue reading

Taxpayer Advocate Advises Don’t Rely on FAQs – Tax Notes

Tax Notes reported that Taxpayer Advocate, Nina Olson, at the Fall ABA Tax Section Meeting advised tax representatives that IRS “FAQ lists on tax topics are too often “a trap for the unwary” and should not be used to sustain a position, which the IRS might have contradicted in a … Continue reading

PLR 201737003 – Foreign Private Foundation Not Subject to Excess Business Holdings Provision

In PLR 201737003, the Service ruled that a foreign private foundation’s holding of a business investment in a foreign corporation that indirectly holds as much as 100 percent of a foreign business entity’s voting stock does not constitute an excess business holding under Code Section 4943 because the foundation won’t … Continue reading

PLR 201737001 + PLR 201737008: Tax Treatment of Trust Judicial Reformation

In two virtually identical PLRs, PLR 201737001 + PLR 201737008, the Service ruled on the tax treatment of the judicial reformation to two trusts. In these PLRs, the Service ruled that a proposed reformation of the trust in question would not cause the trust assets to be included in the spouse’s … Continue reading

Joint Committee on Taxation Report: Present Law And Data Related To The Taxation Of Business

The Joint Committee on Taxation has released its publication, Present Law And Data Related To The Taxation Of Business, summarizing the taxation of business in the US.

See full report by clicking JCX-42-17.

Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.… Continue reading

Grant Thornton Report on Tax Reform for Passthroughs

Grant Thornton has released a report on tax reform for passthroughs that notes that passthroughs  are often taxed at a higher rate than corporations, creating imbalances in the economy, and a solution to this problem must define passthrough business income, tax it at a low and uniform rate, and establish … Continue reading

Rev. Proc. 2017-53: Guidelines Issued on Equivalency Determinations for Public Charity Status

In Rev. Proc. 2017-53, the IRS provides guidelines that tax practitioners may use to prepare written advice on which a domestic private foundation ordinarily may rely in making an equivalency determination that the grantee of a grant made for Code Sec. 170(c)(2)(B) purposes is a qualifying public charity.  The introduction … Continue reading

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