Wealth Strategies Journal

Do More, Better, Faster

Category: Other (page 1 of 94)

Deloitte Survey of Tax Executives: Tax Reform in 2017 – Not Going to Happen

Deloitte surveyed tax executives and the result is deep pessimism about tax reform happening in 2017 along the lines promised by politicians.  The survey, reported by Reuters and picked up by several news agencies begins as follows:

Only a small number of U.S. tax, finance and business professionals expect President

Continue reading

Commentary.Omnibus.2017.08.14: Americans Not Paying Estimated Taxes; Estate Planning Not Just for the Rich; Fiduciary Cases; Are Trusts Still Useful If Estate Tax Repealed; New IRS Criminal Tax Initiatives

Continue reading

Owens v. Commissioner, T.C. Memo. 2017-157: Tax Court Allows Taxpayer $9.5 million bad debt deduction as business bad debt deduction

In Owens v. Commissioner, TC Memo 2017-157, the Tax Court held that a  $9.5 million bad deduction could be claimed as a business bad debt.  The taxpayer argued that he was in the trade or business of lending money. Conversely, the IRS argued that the taxpayer was not  in the … Continue reading

Partial Harmless Error for Wills: Evidence from California by David Horton

David Horton University of California, Davis – School of Law, has made available for download his article, “Partial Harmless Error for Wills: Evidence from California,” published in the Iowa Law Review, Vol. 103, 2018 UC Davis Legal Studies Research Paper.  The Abstract is as follows:

In many legal systems, the

Continue reading

S.1618 – 115th Congress (2017-2018): Would Amend Code to Exclude Employee Owned Stock From Excess Business Holdings for Private Foundation Rules

Debbie Stabenow (D.Mi), has introduced S. 1618, which would exclude employee owned stock from private foundation excess business holding rules. The summary of the proposed legislation is as follows:

Introduced in Senate (07/24/2017)

This bill amends the Internal Revenue Code to exclude certain purchases of employee-owned stock from being considered

Continue reading

Orrin Hatch on Fox Sunday Morning Futures: “We’re going to … hit the rich”

Tax Analysts and the NY Post have reported that Orrin Hatch, Senate Republican tax reform leader, discussed tax reform on Fox News, Sunday Morning Futures, on August 6, 2017.  Among other things, he said that there would be no tax benefits targeted to the wealthy, at one point noting that … Continue reading

PLRs 201731010 + 201731005: GSTT Exemption Allocated to Trust

In PLRs 201731010 + 201731005, the Service allocated GSTT exemption to the trusts in question. The key facts of each, which are identical, are as follows:

On Date 1, in Year 1, Husband created Trust. Trust is an irrevocable trust for the benefit of Husband’s descendants. On Date 2, in … Continue reading

Commentary.Omnibus.2017.08.06:Unsigned Will Is Okay; Billionaires Get Social Security Too; Prenups Increasingly Popular; Supreme Court Leads Way With Online Access; The Malta Pension Plan; Domestic Voluntary Disclosure

Continue reading

Commentary.Omnibus.2017.08.04: Joint Accounts; Is Estate Tax Repeal Bad for You? ; Overview of Private Charitable Foundations; Get Your Electronic Ducks in a Row

  • Joint Accounts: Who Gets the Account Upon Your Death?  An account that is titled in your name and that of your child “with right of survivorship” passes to your child upon your death “by operation of law.” That is, your Will does not control the disposition of this account. When
Continue reading

Mark Meadows + Rand Paul Introduce FACTA Repeal Legislation

Mark Meadows in the House and Paul Rand in the Senate have introduced legislation to repeal FATCA.  The summary of the House bill is as follows:

This bill amends the Internal Revenue Code, with respect to tax administration requirements for foreign-source income and assets, to repeal: (1) withholding requirements for

Continue reading

Quarterly Publication of Individuals, Who Have Chosen To Expatriate, as Required by Section 6039G – Significant Increase – Significant Increase in Rate of Expatriation

Treasury has released its Quarterly Publication of Individuals, Who Have Chosen To Expatriate, as Required by Section 6039G.  Tax Notes, 2017 TNT 148-4, has noted that the number of expatriates in the second quarter of 2017 is almost three times as high as the second quarter of 2016.

See full list … Continue reading

IRS Warning: Don’t Take the Bait, Step 4: Defend against Ransomware

The Internal Revenue Service, state tax agencies and the tax industry have warned tax professionals that ransomware attacks are on the rise worldwide as bad actors here and abroad infiltrate computer systems and hold sensitive data hostage.

The IRS is aware of a handful of tax practitioners who have been … Continue reading

Uniform Directed Trust Act | Charles E. Rounds, Jr.

Charles E. Rounds, Jr, has reported that NCCUSL has approved the Uniform Directed Trust Act on July 19, 2017.

The Uniform Directed Trust Act (the “Act”), approved July 19, 2017 by the National Conference of Commissioners on Uniform State Laws, purports to govern irrevocable directed trusts. For purposes of the

Continue reading

PLR 201730019 and 201730022: CRT – College Endowment Units In CRT Won’t Cause UBTI to College or Trust

In PLR 201730019, the IRS ruled that a contractual arrangement under which a college will issue units in its endowment fund to a CRT, make payments on the units, and be reimbursed to cover costs allocable to the management of the endowment or administration of the CRT, will not generate … Continue reading

PLRs 201730017, 201730018, 201730012: IRS rules on conversion of non grantor trusts to grantor trusts

In PLRs 201730017, 201730018, 201730012, the IRS ruled on conversion of three non grantor trusts to grantor trusts.

The rulings requested were generally as follows:

The information submitted states that on Date 1, Grantor, as settlor and initial trustee, created Trust pursuant to Agreement. Agreement provides that until the X

Continue reading
Older posts