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...
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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....
Continue reading "The Estate Analyst: "Scam Relief for Madoff Victims""
By Martin M. ShenkmanIntroductionRepresentative Pomeroy introduced estate tax legislation with the snappy title "Certain Estate Tax Relief Act of 2009" (H. R. 436). This bill has good and bad news depending on your view of the estate tax. For many...
By Robert Moshman, Esq. Plateau or Pinnacle? Estate tax professionals, welcome to 2009, the promised land! We have made it through nearly the entire estate tax repeal phase-in from 2001 through 2009, the pinnacle of estate tax repeal.Is this...
Continue reading "The Estate Analyst: "Plateau or Pinnacle""
George P. LevendisLevendis Law Group, PLLC Patrick M. SchoshinskiLevendis Law Group, PLLC I. ESTATE PLANNING IN THE CURRENT ECONOMIC ENVIRONMENT A. Fundamental Variables That Are In Significant Flux in the Current Economic Environment • Interest Rates In GeneralAnnuity Discount Rate3.6% (Nov.)...
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By Robert L. Moshman, Esq.Whooosh! Another year has rushed by (except for the months when it dragged on, such as during an endless election, or when oil prices were heading toward $150 per barrel, or when staggering stock market losses...
Continue reading "The Estate Analyst: "The Year In Review, 2008""
Bradley M. Van BurenA tumultuous 2008 - marked by a financial crisis many economists consider to be the greatest since the 1930s coupled with significant challenges on numerous fronts including health care reform, energy independence and the war on terrorism...
The Emergency Economic Stabilization Act of 2008Alvin M. Feit, Esq., CPA and Kevin C. Jones, Esq., CPAWatkins, Meegan, Drury and Company, LLC, Bethesda, MDOn October 3, 2008, Congress passed, and President Bush signed into law, the Emergency Economic Stabilization Act...
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The IRS Continues to Attack Poorly Designed Family Limited Partnership: Estate of Concetta H. Rector
By: Jeff Bae & Craig StephansonValuation Services, Inc.IntroductionThe Internal Revenue Service (the "IRS") won another estate tax case dealing with a family limited partnership ("FLP"). In Estate of Concetta H. Rector (T.C. Memo. 2007-367), the Tax Court held that the...