Wealth Strategies Journal

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Tax provisions in the Senate health care bill

The Journal of Accountancy has posted a summary of the tax provisions of the Senate Health Care Bill.  The summary begins as follows:

Senate Republicans on Thursday released a draft bill that would repeal many provisions of the Patient Protection and Affordable Care Act (PPACA), P.L. 111-148. The Senate bill,

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TaxProf Blog: As More States Kiss Their Estate Taxes Goodby, Will The Push to Repeal Federal Estate Tax Become Irresistible?

The Tax Prof Blog notes that the Wall Street Journal has posted an article discussing the increasing trend among states to eliminate their state estate taxes and questions whether this push will make the push to repeal the federal estate tax inevitable.

See post at: TaxProf Blog

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Leimberg Update: 6/16/17 – 6/21/17: Nevada Asset Protection Planning; 7520 Rates; More

Jay Adkisson, Chris Riser and David Slenn on Transfirst Group, Inc. v. Magliarditi: U.S. District Court Holds that Nevada Law Permits Piercing of Nevada LLLs, Nevada Partnerships, and Nevada Trusts Steve Leimberg’s Asset Protection Planning Newsletter Issue:344    19-Jun-17

7520 and Other Key Rates – July 2017 Steve Leimberg’s Estate … Continue reading

IRS reopens PTIN registration system 

We previously reported that the Service had suspended it’s PTIN registration system after it’s loss in Steele. The Journal of Accountancy now reports that the Service has reopened its PTIN registration system.

The Journal of Accountancy post begins as follows:

The IRS on Wednesday morning reopened its preparer tax

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Bridget Crawford, A Year Behind on Estate & Gift Tax Law Review Articles? Read This Instead.

Professor Bridget Crawford, Pace University, has published an article in Tax Notes Today (subscription required to access), which reviews ten estate and gift tax law articles published in 2016. The articles were the following:

  • Evelyn Brody and Marcus Owens, “Exile to Main Street: The I.R.S.’s Diminished Role in Overseeing Tax-Exempt
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May a vindicated trustee be reimbursed personally from the trust estate even for those defense costs that were covered by his liability-insurance carrier?

Charles E. Rounds, Jr., co-author of Loring and Rounds: A Trustee’s Handbook, writes about whether a vindicated trustee may be personally reimbursed for defense costs from the trust estate even if such costs were covered by his liability insurance carrier.  His post begins as follows:

As to whether the vindicated

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Minnesota Enacts Significant Tax Law Changes

Dorsey & Whitney reports on significant tax changes in Minnesota, including roughly 40 changes to Minnesota’s individual income tax provisions, including: (1) much needed clarity about the effect of the location of a taxpayer’s attorneys, accountants, financial advisers, and bank accounts in the application of Minnesota’s domicile test for determining … Continue reading

PLR 201724007: Ruling on Timing of Gift Splitting + GST Allocations

In PLR 201724007, the Service ruled that  gift-splitting and GST tax decisions made for one year were irrevocable due to the statute of limitations, but because the statute had not expired for a subsequent year reallocations could be made.

See full PLR 201724007 by clicking here.

Posted by Lewis J. Continue reading

Flawed Exempt Org Returns to be Rejected

Tax Analysts is reporting that the Service is likely to soon reject inaccurate or incomplete paper information returns filed by exempt organizations. It notes that “Maria Hooke, director (exempt organizations examinations), IRS Tax-Exempt and Government Entities Division, pointed out that while faulty returns submitted electronically are rejected upfront, the IRS works … Continue reading

Ten Twenty Six Investors v. Commissioner: Partnership Not Entitled to Charitable Contribution Deduction

The Tax Court, in Ten Twenty Six Investors, v. Commissioner, T.C. Memo. 2017-115, held that a partnership was not entitled to a charitable contribution deduction for a conservation easement donation it made. The Court concluded that the perpetuity requirements of Code Sections 170(h)(2)(C) and (5)(A) were not satisfied because the … Continue reading

Leimberg Update: 6/8/17 – 6/15/17: Priv Foundation Handbook, CRT PLRs, Life Ins. Policy Options, Decanting


  • Steve Leimberg – Review of Private Foundation Handbook and Compliance Guide Steve Leimberg’s Charitable Planning Newsletter Issue:264    15-Jun-17
  • Richard Fox: Recently Issued PLRs 201714002 and 201714003 Offer Cautionary Tale to Trustees Failing to Administer Charitable Remainder Trusts in Accordance with Governing Instrument Steve Leimberg’s Charitable Planning Newsletter Issue:263    14-Jun-17
  • Bruce Steiner:
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Kindred Nursing Centers, L.P. v. Clark: Supreme Court Addresses Whether POA May Bind Estate to Arbitration Clause

On May 15, 2017, the US Supreme Court  issued its opinion in Kindred Nursing Centers, L.P. v. Clark. This case addressed the issue of whether an agent acting pursuant to a power of attorney could bind an estate to an arbitration agreement.

The Court’s summary is as follows:

Respondents Beverly

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Tax Reform: Removing Barriers to Small Business Growth – Hearings – U.S. Committee on Small Business & Entrepreneurship

The US Committee on Small Business & Entrepreneurship held a hearing on June 14, 2017, on “Tax Reform: Removing Barriers to Small Business Growth,” at which the AICPA, S Corp Association, and Urban-Brookings Tax Policy Center made recommendations on legislative changes to foster small businesses.

The witnesses included the following … Continue reading

Proposed Centralized Partnership Audit Regulations Finally Released After Regulatory Freeze 

The proposed regulations implementing the new centralized partnership audit regime under the Bipartisan Budget Act of 2015 (BBA) have finally been released. The BBA regime replaces the current TEFRA (Tax Equity and Fiscal Responsibility Act of 1982) procedures beginning in 2018. The proposed regulations were originally issued on January 19 … Continue reading

Thune and Wyden Introduces Bill to Encourage Charitable Giving

U.S. Sens. John Thune, R-S.D., and Ron Wyden, D-Ore,. today introduced the Charities Helping Americans Regularly Throughout the Year (CHARITY) Act, a bipartisan bill that would encourage charitable giving and make it easier for foundations and other tax-exempt organizations to conduct their charitable missions.

Joined by Sens.  R-SD, Bob Casey, … Continue reading

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