Neil I. Rumbak

Forbes, in Ashlea Ebeling's article entitled "States Race To Clean Up Congress' Estate Tax Mess," reports that state legislators in several states are addressing state law issues that could arise due to the repeal of the federal estate tax.  Poste... Read More

The New York Times, in Nicholas Kulish's "Bank Data May Unveil German Tax Evaders, Finance Official Says," reports that the German government has warned Germans with unreported Swiss accounts that they would face punishment if their names appeared on a... Read More

Martin W. O'Toole, partner at Harter Secrest & Emery LLP, has published an article entitled "Trusts & Estates," in the Syracuse Law Review.  According to Wills, Trusts & Estates Prof Blog, "this article is part of a 2007-2008 Survey of... Read More

The New York Times, in Edward Wyatt's "Behind Film's Drama, a Tale Like a Country Song," reports that songwriter Stephen Bruton's will is being contested by his friend, a music producer, and his wife, from whom Bruton filed for divorce. ... Read More

Gerry W. Beyer, Governor Preston E. Smith Regents Professor of Law at Texas Tech University School of Law, and Kimberly Sias, J.D. Candidate at Texas Tech University School of Law, have published an article entitled "What Estate Planners Need to... Read More

Normal 0 false false false EN-US X-NONE X-NONE /* Style Definitions */ table.MsoNormalTable {mso-style-name:"Table Normal"; mso-tstyle-rowband-size:0; mso-tstyle-colband-size:0; mso-style-noshow:yes; mso-style-priority:99; mso-style-qformat:yes; mso-s... Read More

Tax Notes has published an article by Robert W. Wood, attorney with Wood & Porter.  This article examines the "relations-back" election, which retroactively allows for a qualified settlement fund.Posted by Neil I. Rumbak, Associate Editor, Wea... Read More

Tax Notes has published an article by Meg Shreve.  The article explains that Senate Majority Leader Harry Reid has introduced his jobs creation package with "offsets drawn from proposed changes to foreign account reporting rules."  It address... Read More

The United States Tax Court has issued Estate of Oscar Goldberg, Deceased et al. v. Commissioner, a Memorandum Opinion by Judge Mary Ann Cohen.  The Tax Court held that (1) a decedent and his wife owned property as tenants by... Read More

The Department of Justice issued a press release, in which it announced a guilty plea from a Virginia doctor to conspiracy involving an undeclared Swiss bank account.   The press release explained that the doctor pleaded guilty to conspiracy to... Read More

The Tax Policy Center has issued tables that provide the estimates on federal tax distributions for 2010 of income and estate tax cuts for 2001 through 2008 with the alternative minimum tax patch.See also Tax Policy Center Releases Estimates on... Read More

The Tax Policy Center has issued tables that provide, according to Tax Analysts, "estimates of the impact on federal tax distribution of Obama administration budget proposals affecting individual and corporate taxation, including extending the earned i... Read More

Tax Notes has published an article by Wendy C. Gerzog, Professor of Law at the University of Baltimore School of Law.  The article analyzes Pierre V. Commissioner and discusses the relationship between check-the-box regulations and the gift tax.Se... Read More

The Senate has approved the Hiring Incentives to Restore Employment (HIRE) Act, which is composed of $15.billion in tax incentives that are intended to encourage employment.  The House of Representative's passage of the HIRE Act seems improbable.&... Read More

Tax Notes has published an article by Jay Starkman, CPA.  The article emphatically states that retroactive tax law is constitutional, and provides historical support and case precedent for this premise.    See Jay Starkman, "Can an Estat... Read More

Phillip Karpel, of Olincy & Karpel, wrote a correspondence to the IRS in response to Notice 2010-19 and in response to Conrad Teitell's February 5, 2010 correspondence to the IRS.  The correspondence stresses the discouragement that Notice 201... Read More

Max Baucus, Senate Finance Committee Chair, commended the Senate for the passage of the Hiring Incentives to Restore Employment (HIRE) Act.  Baucus said that the HIRE Act is a "targeted approach that will cut taxes for businesses, helping them gro... Read More

Erik Dryburgh, principal at Adler & Colvin, wrote a correspondence to the IRS in response to Notice 2010-19.  The correspondence mentions that Notice 2010-19 does not address Section 2511(c)'s impact on charitable remainder trusts.  It pr... Read More

The IRS has issued Announcement 2010-16.  Announcement 2010-16 suspends for persons who are neither U.S. citizens, U.S. residents, nor domestic entities (corporations, partnerships, trusts, and estates) the requirement to file a Report of Foreign ... Read More

The IRS has released Notice 2010-23.  Notice 2010-23 provides administrative relief in regard to Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts ("FBAR") filings for certain persons.  First, a person having signature authorit... Read More

According to Richard E. Neal, House Ways and Means Select Revenue Measures Subcommittee Chair, the House Ways and Means Select Revenue Measures Subcommittee will conduct in 2010 a study on transfer pricing.  See Chuck O'Toole, "Select Revenue Meas... Read More

In a letter to the IRS and to the Financial Crimes Enforcement Network, Department of Treasury, Jordan Weiss of Roll International Corporation has requested to expand the exemption, noted in Notice 2009-62, from filing a Report of Foreign Bank and... Read More

The Congressional Budget Office (the "CBO") has prepared a report to House Budget Committee ranking minority member Paul Ryan.  In the report, the CBO maintains that if (i) the tax provisions of EGTRRA and JGTRRA, except for those related to... Read More

The Congressional Budget Office (the "CBO") has prepared a report to House Budget Committee ranking minority member Paul Ryan.  In the report, the CBO maintains that if (i) the tax provisions of EGTRRA and JGTRRA, except for those related to... Read More

The Senate has prepared an Amendment to H.R. 4154, the American Workers, State, and Business Relief Act of 2010. Posted by Neil I. Rumbak, Associate Editor, Wealth Strategies Journal.... Read More

Normal 0 false false false EN-US X-NONE X-NONE MicrosoftInternetExplorer4 /* Style Definitions */ table.MsoNormalTable {mso-style-name:"Table Normal"; mso-tstyle-rowband-size:0; mso-tstyle-colband-size:0; mso-style-noshow:yes; mso-style-priority:99; m... Read More

The IRS and Treasury have extended and revised rules regarding who must file a TD F 90-22.1, Report of Foreign Bank and Financial Accounts ("FBAR").  In addition, the IRS continued the suspension of filing an FBAR for anyone who is... Read More

Steve Akers, Associate Fiduciary Counsel, Bessemer Trust, provides the following summary of Estate of Shurtz v. Commissioner, T.C. Memo 2010-21 (February 3, 2010): "In a case involving the creation of a family limited partnership to hold undivided inte... Read More

The Court of Federal Claims, in Curtin et al. v. U.S., has dismissed a claim brought by two executors of an estate for the issuance of a replacement check from the IRS for a refund that the two executors claim... Read More

The IRS has asked for public comment on Form 1041.  See also Comments Requested on Estate Income Tax Return, 2010 TNT 43-54, March 5, 2010.Posted by Neil I. Rumbak, Associate Editor, Wealth Strategies Journal.... Read More

The U.S. Congress Joint Economic Committee's Weekly Economic Digest reports on the stabilization of the U.S. labor market.  It reports that "payrolls essentially unchanged, despite winter storms," "unemployment rate hold steady," and "underutiliza... Read More

Richard Nenno, Managing Director and Trust Counsel, Wealth Advisory Services, Wilmington Trust Company, wrote a correspondence to the Treasury and IRS.  The correspondence requests that the Treasury or IRS issue a notice or regulation exempting ap... Read More