Second Circuit Reins in Section 2036 Mother Continuing to Share Property with Son Does Not Constitute "Enjoyment and Possession"By: Espen Robak, CFA of Pluris Valuation AdvisorsIn our currently stressed economic circumstances there may be a parent or two who feels...
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Editor's Note: This is the second in a six-part series by Wendy Goffe of Graham & Dunn that will be published weekly through September.PART II: AN INTRODUCTION TO LESSER KNOWN BUT USEFUL TRUSTS By: Wendy Goffe, Graham & DunnI. Commercial Trusts.The...
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Editor's Note: This is the first in a six-part series by Wendy Goffe of Graham & Dunn that will be published weekly, now through September.AN INTRODUCTION TO LESSER KNOWN BUT USEFUL TRUSTSBy: Wendy S. Goffe, Graham & Dunn, Seattle, WAI....
Continue reading "Part I: An Introduction to Lesser Known But Useful Trusts"
By: Espen Robak, Pluris Valuation Advisors In Estate of Hilde E. Erickson, TCM 2007-207 (April 30, 2007), the IRS determined a $734,599 Federal gift tax and a $718,320 Federal estate tax deficiency of the estate of Mrs. Hilde E....
Continue reading "Another "Bad Facts" Victory For The IRS In Estate of Erickson"
Also: Michael Jackson's Estate Revisited and Other Celebrity Estates By Robert L. Moshman, Esq. "Ready? 1,2,3,4 This is it, Here I stand I'm the light of the world I'll feel grand Got this love, I can feel And...
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By Terry Philip Segal and Michael M. Mustokoff At present, many American taxpayers who have or had undeclared UBS Swiss bank accounts, as well as undisclosed accounts in other foreign banks, run a risk of criminal prosecution or...
By: Ori Bash, ASAIn Ludwick v. Comm'r, TC Memo 2010-104, the Service struck a major blow for its favored approach to undivided interests, not only winning acceptance of its "cost to partition" approach, but winning the argument on most of...
By Jeffrey Rubinger and Summer Ayers LePreeOn March 26, 2009, the Internal Revenue Service announced a six-month reduced-penalty voluntary compliance initiative available to U.S. taxpayers with unreported offshore income.Background: The UBS CaseIn connection with the U.S. government's investigation of and...
By Jeffrey "Jeff" RubingerOn December 22, 2008, the IRS issued proposed regulations (the Proposed Regulations) (REG-113462-08) under Regulation Section 1.881-3 that "clarify" that the term "person" includes an entity that is disregarded as an entity separate from its single owner...
By Robert L. MoshmanCharles Ponzi is experiencing a renaissance of interest lately thanks to the exploits of Bernard Madoff. In December, 2008, Madoff was accused of losing $50 billion of investments for his clients utilizing a Ponzi or pyramid scheme....
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