In Private Letter Ruling 201323007 (released June 7, 2013), the IRS stated that the funding of the CLAT was a completed gift; the taxpayer was entitled to a gift tax deduction; and no portion of the CLAT’s property would be included in the taxpayer’s gross estate....More
Ironically, while most Americans cheered ATRA’s permanent relief from federal estate taxes, these tax law changes were met with a mixture of fear and self-doubt by one small segment of the population. Quietly, a group consisting of...More
The Internal Revenue Service issued Revenue Ruling 2013-14, holding that a fideicomiso, or “Mexican Land Trust” isn’t a “trust” for U.S. tax purposes....More