Isaac Pflaum

The article Some States Propose to Eliminate Tax Breaks for Seniors draws attention to State proposals to eliminate exemptions for IRA distributions and pensions. Facing large budget deficits, politicians in Michigan, Georgia and H... Read More

According to recent reports, numbers released by the Treasury Department indicate that the number of individuals expatriating from the United States in 2010 was more than double that in 2009. Taxpayers that renounce their U.S. citizenship or terminate ... Read More

In the report, Actions Are Needed in the Identification, Selection, and Examination of Individual Tax Returns With Rental Real Estate Activity (2011-30-005), the Treasury Inspector General for Tax Administration ("TIGTA") calls for increased ... Read More

Gary Beyer reports that Manhattan prosecuters have denied a request by "officious interlopers" to appoint a guardian for Hughette Clark. Investigators met with Ms. Hughette, finding that she is "not lucid," and are investigating how Clark's $500 millio... Read More

The ABA Section of Real Property, Trust and Estate Law is sponsoring a 90-minute teleconference and live audio webcast, Preparing the Fiduciary Income Tax Return on March 17, 2011During this presentation, participants will:Learn the differences between... Read More

Graeme Wood has written an article, Secret Fears of the Super-Rich, The Atlantic Magazine, April 2011.The article discusses a recent study entitled "The Joys and Dilemmas of Wealth," suggesting that assets in the tens of millions of dollars a... Read More

In Revenue Ruling 2011-10, the IRS provides the April 2011 prescribed applicable federal rates for purchases under sections 1274(d) and 1288(b) as well as the adjusted federal long-term rate and the long-term tax... Read More

Omar T. Mohammedi (Attorney at Law, New York, NY) recently published his article entitled Shariah-Compliant Wills:  An Overview, 25 Prob. & Prop. 58 (Jan./Feb. 2011). In the article Mohammedi discusses how ensuring an estate dis... Read More

The State Bar of Texas is sponsoring the Advanced Elder Law 2011 and Advanced Guardianship Law 2011 courses in Houston on April 7-8, 2011.Highlights include:Healthcare Reform ActSocial Security Benefits and Your ClientsElder Ab... Read More

In Etchinson v. Commissioner, T.C. Summ. Op. 2011-30; No. 4110-08S, The Court ruled that the taxpayer failed to produce any substantiating documents to support any of the deductions in dispute. According to the taxpayer, her records were stolen from a... Read More

IRS Publication 559 (rev. 2010), which helps in the administration of estates by providing guidance on 2010 changes to Public Law 111-312, Act section 301 including:1. Reinstatement of the estate tax for 2010,2. Repeal of the modified ca... Read More

In the article IRS Targets Family Real Estate Transfers, Forbes columnist William P. Barrett reports that the IRS has filed suit in a California district court seeking access to the California state tax agency database of on everyone who transferred... Read More

In the article The Inheritors, Forbes Columnist Ashlea Ebeling provides advice to baby boomers on spending their $8.4 trillion inheritence. Ebeling offers several anecdotes as well as advice from financial professionals regarding the treatment of asse... Read More

In the article The Price of Taxing the Rich, Wall Street Journal columnist Robert Frank discusses the extreme volitility of tax revenues in states relying too heavily on the top 1% of earners for revenue. States such as New York... Read More

The article Nevada's Banking Regulator Tells Lawmakers Tough Laws More Important than More Business, discusses the controversial tenure of Nevada Banking Commissioner George E. Burns. In a recent showdown with the State's legislature Burns opposed loss... Read More

In the article, Guilty Verdicts Appealed in Brooke Astor Will Case, New York Times columnist John Eligon reports that Ms. Astor's son and attorney have appealed their conviction for multiple counts of fraud and larceny in connection with thei... Read More

In the article The New Grave Robbers, New York Times opinion columnist Ray Madoff explores the business of licensing the names and  images of deceased celebrities. According to Madoff, the so-called "right of publicity" attached to the estate... Read More

IRS Release IR-2011-33:  The Treasury Department and the IRS announced today that Form 8939 is not due on April 18, 2011, and should not be filed with the final Form 1040 of persons who died in 2010. New guidance that announces... Read More

In the article Wills and Trusts: Which Will You Trust for Your Estate Planning?, Linda Covella discusses the relative strengths and weaknesses of living trusts. The author argues that living trusts help to avoid probate, insure privacy and offer a... Read More

Tax Tip 2011-67 shares 10 important things the IRS wants you to know about making tax payments correctly:Never send cash!If you file electronically, you can file and pay in a single step by authorizing an electronic funds withdrawal via tax... Read More

In a recent press release Brian Miller, executive director of United for a Fair Economy (UFE), lauds a recent letter from the Congressional Progressive Caucas, which includes proprosals such as a progressive estate tax and an higher marginal tax rates... Read More

In the recent article "Q. and A.: The Differences Between Philanthropy in the West and the East," New York Times Columist Sonia Kolesnikov-Jessop interviews Noor Quek, founder of NQ International, a Singapore firm providing advisory sevices to family o... Read More

Proposed IRS regulations that would require banks to report interest paid to non-US resident depositors have provoked comments from state officials and bankers.J. Thomas Cardwell of the Florida Office of Financial Regulation expressed his con... Read More

In a recent press release, Republicans on the House Ways and Means Committee said that contrary to rhetoric from the Obama administration that no middle-income tax increases would be enacted, President Obama and Congressional Democrats have e... Read More

In a recent press release Responsible Wealth announced the launch of Tax Wealth Like Work," a joint campaign with United for a Fair Economy. The organizations are seeking to change the capital gains and dividend tax rate to "the sam... Read More

The IRS recently proposed regulations relating to the exclusion from gross income under section 108(a) of discharge of indebtedness income of a grantor trust or an entity that is disregarded as an entity separate from its owner. The proposed regul... Read More

In a recently published book, "Treasure Islands: Offshore Banking and Tax Havens," author Nicholas Shaxson investigates how banks, multinational corporations and wealthy individuals have come to use off-shore tax havens to "maximize their own rewards" ... Read More

A recent article by Ellen P. Aprill, Professor of Tax Law at Loyola Law School, reports on the costs and benefits of registering a congressional legal defense fund as a s Section 527 organization. The report concludes that contributions to... Read More

A recent report from the Congressional Budget Office ("CBO") estimates that under President Obama's budget proposal the deficit will grow by $2.8 trillion over baseline projections by the year 2021 to a total of $9.5 trillion. The CBO estimated that... Read More

House Ways and Means Committee member David G. Reichert, R-Wash., has introduced the S Corporation Modernization Act of 2011, H.R. 1478, which would reform the tax treatment of S Corporations. The bill would amend the Internal Revenue Code of... Read More

In a recent article, Robert S. Chase II, Carol P. Tello, and Dwaune L. Dupree discuss the final foreign bank account report ("FBAR") regulations released on February 24, 2011. The authors argue that despite the fact that the final FBAR... Read More

On April 25, 2011, the IRS announced that it has taken action against 19 of the more than 700,000 tax return preparers who registered with the IRS as part of the agency's new oversight regime. The 19 unnamed prepares failed... Read More

Colorodo Democratic Representative Jared Polis has introduced the Investment Property Opportunity Act of 2011, H.R. 1481. If enacted the bill would amend the Internal Revenue Code of 1986 to encourage the purchase of residential property by providing a... Read More

The April 18, 2011 Fact Sheet, details how tax cuts passed by the Democratically controlled Senate have resulted in the lowest tax burden in 60 years.  The article details the various measure that have been enacted including the&nbs... Read More

In a recent Letter to the Editor of Tax Notes Today, Robert Feldgarden examines the recent Tax court decision in Tempel v. COmmissioner. The Court held that a state tax credit is a capital asset when sold, but the income included  85... Read More

The Tax Court has held that the estate of Gertrude Saunders was not entitled to deduct $ 30 million for a claim arising from a suit against the deceased  woman's late husband. The court found that the value of the... Read More

The Tax Court has held that an estate had properly applied the income capitalzation method to determine the fari market value of the decenent's real property. The IRS had disputed the estate's calculation finding a significant deficency which the Court... Read More

The Tax Court has denied a marital trust discount and Section 2053 deduction to an estate including a frozen marital trust. The Court found that the estate was not entitled to a discount for lack of marketability or control but... Read More

The IRS and Treasury officials have asked for further public comment on proposed regualtions to impliment the Foreign Account Tax Compliance Act. Specifically, comments relating to the treatment of existing entity accounts and definitional issuers rela... Read More

In a letter addressed to Democratic members of the House Ways and Means Committee, dated April 29, IRS commissioner Douglas Shulman state that the IRS would review the innocent spouse provision under section 6015(f), which provide relief to joint taxpa... Read More

A recent report from K&L Gates, LLP, suggests that foreign finacial institutions are finding it difficult to impliment the Foreign Account Tax Compliance Act, dispite guidance provided by the IRS. The Act is intended to reduce tax avoidance by corp... Read More

In a recent article discussing the prosecution of seven former UBS AG clients, Kevin E. Thorn, managing partner of the Thorn Law Group, a tax litigation firm based in Washington, suggests that sentences for offshore account reporting violations will in... Read More

In a recent unpublished opinion, the United States Court of Appeals for the Ninth Circuit affirmed the Tax Court's holding in Estate of Erma V. Jorgensen et al. v. Commissioner. In Estate of Erma, the Tax Court held that amounts... Read More

The U.S. District Court for the Southern District of Texas has granted in part and denied in part Plaintiffs post-trial motion to amend the Court's August 20, 2009 Findings of Fact and Conclusions of Law in Thomas Lane Keller et... Read More

In a recent press release, the Internal Revenue Service has clarified the reporting rules relating to family members of a client with a private banking account at a foreign bank under the Foreign Account Tax Compliance Act ("FACTA"). Such family... Read More

In a recent artcile, Jeremiah Coder examines the disposition of several recent Circular 230 disciplinary proceedings. Mr. Coder concludes that practitioners should take allegations of ethical violations by the IRS Office of Professional Responsibility ... Read More

In a recent statement, Senator Max Baucus, D-Mont., said that the Senate Finance Committee, which he chairs, will consider whether to elliminate at least some of the tax advantages of pass through entities by taxing them as corporations. The statement... Read More

In a recent decision, Rahall v. Zima the Tax Court upheld penalties for failure to file returns and for fraud in connection with the failure to recognize taxable (non-corpus) income from several domestic and foreign trusts. The court also denied c... Read More

In a recent article, David van den Berg of Tax Analysts reports that the IRS has begun examinations of five donors who did not file gift tax returns for their donations to section 501(c)(4), "social welfare" organizations. According to the IRS,... Read More

The recent holding of the Fifth Circuit in Levy v. United States has been appealed on writ of certiorari to the United States Supeme Court. The petitioner seeks review of the Circuit's decision in an estate tax refund suit, arguing that ... Read More

In a recent revenue ruling, the IRS concluded that the shares of a qualified subchapter S trust (QSST) created upon the death of the electing benificiary are treated as a separate trust for purposes of section 1361(d). The IRS further concluded... Read More

In a recent revenue ruling, the IRS issued seven rulings regarding the renouciation, and gift taxation of divided qualified terminable interest property trusts (QTIPs). According to the IRS, the division of marital trust pursuant to applicable Sta... Read More

A May 13 release by Adler & Colvin expresses the view that the IRS has engaged in a "sudden, unannounced initiative to retroactively enforce gift tax" on contributions to non-charitable 501(c) groups pursuant to a 1982, IRS ruling the IRS "had... Read More

A May 18th report by the Office of Personnel Management covers significant proposed IRS regulations and changes, including:1) Changes to the deductibility of certain investment advisory and other expenses of trusts and estates, specifically whether suc... Read More

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