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Commentary Omnibus.2017.09.22: Dealing With Clients Wanting Discounts; 2018 Tax Rates; Estate Tax Portability; Protecting Yourself From Equifax Hack; Surviving Identity Theft; Residency Tax Planning for Noncitizens

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Borrowing in the Shadow of Death: Another Look at Probate Lending by David Horton 

David Horton has made available for download his article, “Borrowing in the Shadow of Death: Another Look at Probate Lending,” to be published in the William & Mary Law Review, Vol. 59, 2018. The Abstract is as follows:

“Fringe” lending has long been controversial. Three decades ago, demand for subprime credit soared,

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PLR 201737003 – Foreign Private Foundation Not Subject to Excess Business Holdings Provision

In PLR 201737003, the Service ruled that a foreign private foundation’s holding of a business investment in a foreign corporation that indirectly holds as much as 100 percent of a foreign business entity’s voting stock does not constitute an excess business holding under Code Section 4943 because the foundation won’t … Continue reading

What Rothification Means for Tax Reform – Tax Foundation

The Tax Foundation has released its report, “What Rothification Means for Tax Reform.”  The report begins as follows:

Rothification is the compulsory conversion of some or all traditional defined-contribution plans to Roth-like plans. While that definition can seem like a mouthful, it may soon be important to understand the concept

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ACTEC Proposal Concerning Federal Estate Tax Recovery Provisions

ACTEC has submitted a report to the key Congressional tax committees  that recommends that the federal estate tax recovery provisions in the Internal Revenue Code be amended in order to eliminate inconsistencies and to expand.

See full report by clicking ACTEC Proposal Concerning Federal Estate Tax Recovery Provisions (August 7, 2017).

Posted … Continue reading

ACTEC – Comments on Eligibility of Trusts to Participate in an Election Out of the Partnership Audit Rules under New Section 6221

ACTEC released it comment on proposed partnership audit regulations (REG-136118-15), suggesting that the IRS allow trusts to be eligible partners when determining a partnership’s eligibility to opt out of the new rules, noting that adding trusts to the class of qualified partners wouldn’t increase the audit burdens.

See full comment … Continue reading

2017.09.13.Tax Reform Update – Estate Tax Repeal – Family Business Coalition + Center on Budget and Policy Priorities

See following estate tax repeal lobbying letters/posts by clicking on links:

Family Business Coalition: The estate tax provides very little federal revenue, is unfair to families, and is opposed by a supermajority of likely voters, and eliminating the tax would create jobs and grow the economy.

Center on Budget and Continue reading

IRS Security Recommendation: Make Data Security an Everyday Priority; Key Steps Can Help 

The IRS, state tax agencies and the tax industry today urged tax professionals to make data security an everyday priority, noting a few simple steps can go far in protecting taxpayer information from cybercriminals.

Cybersecurity experts often refer to the 90/10 rule. This rule states that 10% of cybersecurity is … Continue reading

Commentary.Omnibus.2017.08.29: Using Disclaimers; Robot Led Funerals, Reverse Veil Piercing and More

  • How to Use Trust Disclaimers in Estate Planning.  When considering drafting a will or trust document, testators and settlors typically seek out the professional advice of an attorney. This stems from the fact that lawyers are the only persons legally allowed to perform many of the tasks required…
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310 Retail LLC et al. v. Commissioner: Deed Contemporaneous Written Acknowledgment of Conservation Easement

In 310 Retail, LLC, Zeller-310, LLC, Tax Matters Partner v. Commissioner, the Tax Court granted an LLC’s partial motion for summary judgment in a conservation easement case, finding that the donee executed a deed of easement contemporaneously with the gift, and that the deed satisfied the contemporaneous written acknowledgement requirement … Continue reading

Fiscalini v. Commissioner: Court Finds Part Gift Part Sale in Home Transfer

The Tax Court, in Fiscalini v. Commissioner, T.C. Memo 2017-163,  sustained an addition to tax and a penalty, holding that the taxpayer  must recognize capital gain from the sale of his home to his parents, finding that his adjusted basis should include his parents’ basis in their interest they gifted … Continue reading

Estate Not Allowed a Deduction for Unpaid Gift Tax Related to a Net Gift 

Ed Zollars summarizes Estate of Sheldon Summers, where the Tax Court disallowed a deduction for unpaid gift tax related to a net gift.  Ed Zollars’ summary begins as follows:

When a taxpayer has made a “net gift” within three years of the taxpayer’s death, how is that gift handled

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Avrahami v. Commissioner: Tax Court Disallows Captive Insurance Premium Deductions

In Avrahami v. Commissioner, 149 TC No. 7  (Aug. 21, 2017), the Tax Court disallowed a couple’s insurance premium deductions for amounts paid to a purported captive insurance company, finding that the entity was not an insurance company.  The Tax Court also held the couple liable for taxes on unreported … Continue reading

Estate of Sheldon Summers v. Commissioner: Gift Tax Due at Death Not Deductible + Apportionment of Estate Tax Under NJ Law Not Allowed

The Tax Court, in Estate of Sheldon Summers v. Commissioner, 149 T.C. No. 8 (Aug. 22, 2017),  with Judge Halpern writing the opinion, held that an estate was not entitled to deduct the gift tax owed at the time of a decedent’s death for gifts made to the decedent’s nieces, … Continue reading

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

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