Bloomberg, in an article titled "Business Lobbyists Push to Revive Estate Tax They Tried to Kill," reports that the National Federation of Independent Business and the Associated General Contractors of American are calling on Congress to reinstate the estate tax...
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The federal estate tax's great hibernation of 2010 is having a significant impact on the estate taxes of certain states. Indeed, state estate taxes that piggy-back the current federal estate tax are sleeping with it this year. And in some...
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Steve Akers, Associate Fiduciary Counsel, Bessemer Trust, provides the following summary of Estate of Shurtz v. Commissioner, T.C. Memo 2010-21 (February 3, 2010): "In a case involving the creation of a family limited partnership to hold undivided interests in timberland...
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The Senate has prepared an Amendment to H.R. 4154, the American Workers, State, and Business Relief Act of 2010. Posted by Neil I. Rumbak, Associate Editor, Wealth Strategies Journal....
In a February 24 report to Congress, IRS Commissioner Douglas Shulman stated that high-wealth individuals and their related businesses operating on a global basis should expect greater scrutiny in the years to come. In 2009, the IRS launched the Global...
Erik Dryburgh, principal at Adler & Colvin, wrote a correspondence to the IRS in response to Notice 2010-19. The correspondence mentions that Notice 2010-19 does not address Section 2511(c)'s impact on charitable remainder trusts. It provides an example to prove...
Phillip Karpel, of Olincy & Karpel, wrote a correspondence to the IRS in response to Notice 2010-19 and in response to Conrad Teitell's February 5, 2010 correspondence to the IRS. The correspondence stresses the discouragement that Notice 2010-19 will have...
Tax Notes has published an article by Jay Starkman, CPA. The article emphatically states that retroactive tax law is constitutional, and provides historical support and case precedent for this premise. See Jay Starkman, "Can an Estate Tax Be Retroactive?"...
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Howard M. Zaritsky wrote to the Estate and Gift Tax Attorney-Advisor, Office of Tax Policy, U.S. Department of Treasury, a correspondence that appears to address Notice 2010-19. The correspondence states "a charitable remainder trust cannot be a grantor trust, so...
Steve Akers, Associate Fiduciary Counsel, Bessemer Trust, provides the following summary of Price v. Commissioner, T.C. Memo 2010-2 (January 4, 2010): Gifts of limited partnership interests by parents to their three children did not constitute present interest gifts that qualify...
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Steve Akers has written an extensive outline of his observations of the 44th Annual Philip E. Hecklerling Institute on Estate Planning. The introduction to the outline, Heckerling Musings 2010, is below:"The 44th Annual Philip E. Heckerling Institute on Estate Planning...
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In PLR 201006009, the IRS allowed a married couple an extension to allocate available generation skipping tax exemptions to a transfer to two trusts due to the facts that (1) the couple's attorney failed to advise the couple for the...
In PLR 201006008, the IRS allowed a married couple an extension to allocate available generation skipping tax exemptions to a transfer to two trusts due to the facts that (1) the couple's attorney failed to advise the couple for the...
In PLR 201006005, the IRS ruled that certain modifications to a trust, pursuant to a court-sanctioned settlement agreement, cause neither the trust nor distributions to the trust to be subject, pursuant to Section 2601, to the generation-skipping tax. Normal 0...
In PLR 201006023, the IRS ruled that certain modifications to a trust, pursuant to a court-sanctioned settlement agreement, cause neither the trust nor distributions to the trust to be subject, pursuant to Section 2601, to the generation-skipping tax. Normal 0...
Paul Caron has posted an article titled "Ten Estate Planning Advantages of Limited Liability Companies," 70 Tax Notes 998 (1996), on SSRN. The abstract is below: "In the eight years since the Service blessed the Wyoming limited liability company (LLC) statute, there...
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A letter from Conrad Teitel, an attorney with Cummings & Lockwood LLC, urges Senator Max Baucus and Senator Chuck Grassley to work with Congress to repeal the modified carryover basis rules in place for 2010 retroactively to January 1, 2010. ...
Some taxpayers may have needed to take an early distribution from their retirement plan last year. The IRS wants individuals who took an early distribution to know that there can be a tax impact to tapping your retirement fund. Tax Tip...
The Fiduciary Advisory Services Group of McGuireWoods LLP recently made available the following release, which provides information on a number of fiduciary cases throughout the country. Posted by Joshua Hock, Associate Editor, Wealth Strategies Journal...
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Family Business Magazine and Stetson University's Family Enterprise Center are joining together to present a new joint, "Transitions: The Changing Environment for Family Companies," to be held April 15-16 at the Celebration Hotel in Celebration, Florida. The conference will be...
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