TIGTA issued a report that says that IRS guidance, classification sheet documentation, and oversight of estate and gift tax return examinations must be improved. It’s report includes specific recommendations for improvement.
See full TIGTA Report by clicking here.
Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.
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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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
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 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).
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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.
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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
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
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
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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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