McGuire Woods Fiduciary Cases – January 2, 2018

McGuire Woods has made available for download itsJanuary 2, 2018 white paper summarizing several recent fiduciary court cases. The Abstract of cases summarized is as follows:


In the most recent installment of the McGuireWoods Fiduciary Advisory Services annual multipart series on recent fiduciary cases, developments in the law concerning … Continue reading

Rafizadeh v. Commissioner, 150 TC 1: Extended Statute of Limitations Under Section 6501(e)(1) Not Applicable to Income Earned on Foreign Financial Assets

In Rafizadeh v. Commissioner, 150 TC 1, the Tax Court held that the extended statute of limitations under Section 6501(e)(1) does not apply to income earned on foreign financial assets.  The case summary is as follows:

I.R.C. sec. 6038D, enacted on Mar. 18, 2010, and effective for taxable years beginning after

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Tax Notes, Martin A. Sullivan: Economic Analysis: Can Charitable Deductions to States Replace Lost SALT Deductions?

Tax Notes’ Martin A. Sullivan analyzes whether states may restructure their revenue sources to encourage deductible charitable contributions in lieu of non-deductible SALT payments. His article concludes as follows:

Many states already provide tax credits for charitable contributions to funds that serve a public purpose and can save the states

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PLR 201750004: Trust is Valid See Through Trust

In PLR 201750004, the IRS ruled that a subtrust that was the named beneficiary of retirement accounts was a valid see- through trust and, therefore, the required minimum distributions for the applicable retirement accounts are to be calculated based on the life expectancy of the sole designated beneficiary of the … Continue reading