Wealth Strategies Journal

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IRS Revises Delegation Order On Estate Tax Transfer Certificates

The IRS recently revised an earlier order, delegating to specialty programs estate and gift tax group managers and a director the authority to issue transfer certificates in some estate tax cases.

See Tax Analysts, “IRS Revises Delegation Order On Estate Tax Transfer Certificates,” 2014 TNT 189-14 (Sept. 20, 2014).… Continue reading

U.S. District Court Rules Taxpayer’s Retained Expert’s Opinion Based on Inadmissible Hearsay Documents Is Admissible and Relevant to Determining Whether Taxpayer Owed Federal Income Taxes

Plaintiff, United States of America, (“plaintiff”) sought judgment against lead defendant James B. Hughes (“Hughes”)for his 1999, 2000, 2001, 2002, 2003, 2004 and 2006 federal income tax liabilities. Plaintiff also sought to establish and enforce federal tax liens on three properties belonging to lead defendant Hughes and his sister, co-defendant … Continue reading

In re Kevin Jerome Briggs: U.S. Bankruptcy Court Provides Guidance Whether Income Tax Related Debts Are Non-Dischargeable in a Chapter 7 Proceeding

On June 9, 2014, the United States Bankruptcy Court, Northern District of Georgia, Atlanta Division, granted in part and denied in part, Defendant Internal Revenue Service motion for summary judgment in the adverserial proceeding portion of a Chapter 7 case involving the debtor and plaintiff, Kevin Jerome Briggs, Sr., and … Continue reading

IRS Releases Summer 2014 Issue of the Statistics of Income Bulletin

The Internal Revenue Service recently announced that the summer 2014 issue of the Statistics of Income Bulletin is now available at IRS.gov. This Bulletin provides the most recent data available from various tax and information returns filed by U.S. taxpayers. The current issue has articles covering the following topics:

  • Foreign-Controlled
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Changes to IRS Appeals Process

Effective Sept. 2nd, the IRS Office of Appeals is changing the way it handles appeals to examination decisions.   Pursuant to the new Appeals Judicial Approach and Culture (AJAC) project, IRS appeals officers are no longer going to function as examiners or investigators.  The IRS Office of Appeals will now Continue reading

Improper Assignment Is Not A Basis for Trustee Liability

This opinion holds that an improper assignment is not a basis for trustee liability.  In this case, a trust beneficiary assigned his interest in the trust for the benefit of other beneficiaries in exchange for a cash payment from the trust,  even though the trust had a valid spendthrift provision … Continue reading

How to Protect Gifts and Inheritances From Divorce Settlements

Whether a particular asset can be divided as part of a divorce settlement depends on how it is classified: separate property or marital property.  State laws governing property differ in details.  Generally speaking, separate property includes inheritance received by either spouse.  Yet the critical consideration is whether the inheritance – … Continue reading

Two Documents Every Young Adult Should Sign

If you are the parent of a young adult that is about to leave home for college or attend a gap-year program, you should ask your young adult to sign a durable power of attorney and a health care proxy.  These are estate planning documents that are equally essential for … Continue reading

A Recurring Problem with Benefit Plan Administration

A recurring problem in the world of benefit plan administration is an incorrect or unrevised beneficiary designation form. Many participants complete their beneficiary designations incorrectly because they don’t read the instructions carefully or don’t understand the instructions. Beneficiary designation forms are often filed away without review, and mistakes surface after … Continue reading

IRS Releases Supplemental Instructions for FACTA Compliance

“The IRS has released instructions for the requester of Forms W-8BEN, W-8BEN-E, W-8ECI, W-8EXP, and W-8IMY, which supplement the instructions for those forms and help withholding agents and foreign financial institutions validate the forms for purposes of chapter 3 and the Foreign Account Tax Compliance Act requirements.  The instructions also … Continue reading

CBPP Claims Marginal Tax Rates Can Be Deliberately Misconstrued By Third Parties

Tax Notes has recently published an article by Arloc Sherman of the Center of Budget and Policy Priorities, (“CBPP”), where the author suggests that policymakers desirous of having a frank and open discussion focused on tax reform and lowering general marginal tax rates should stop exaggerating the effect of marginal … Continue reading

IRS cautions that Section 121(d)(11) of the Internal Revenue Code is not wholly repealed

Section 121(d)(11) generally provides that for property acquired from a decedent, or the decedent’s estate or trust, the taxpayer may take into account the ownership and use by the decedent for determining eligibility to exclude gain on the sale or exchange of the property.  Section 121(d)(11) was enacted in 2001 … Continue reading

FATCA and its effect on increasing numbers of expatriates renunciating their U.S citizenship

The deVere Group recently conducted a survey of 414 American expatriate clients, and 79% of the group said they had ‘actively considered’, ‘are thinking about,’ or ‘have explored the options of’ renouncing their US passport due to the implications of the Foreign Account Tax Compliance Act (FATCA), which came into Continue reading

Tax Court holds Petitioner Cannot Exclude Social Security Benefits From Gross Income On Petitioner’s Income Tax Return

This case involved the technical confluence of the taxability of social security benefits and general non-taxability of private insurance disability benefits.  Petitioner applied for and began to receive long term disability benefits from a private insurer in 2007.  Petitioner’s insurance policy provided that petitioner’s benefits would be reduced if she … Continue reading

Congressional Research Service

The Congressional Research Service (CRS) works exclusively for the United States Congress, providing policy and legal analysis to committees and Members of both chambers of Congress, regardless of party affiliation.  As a legislative branch agency within the Library of Congress, CRS is a valued and respected resource on Capitol Hill. … Continue reading

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