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Based on Price and Fisher, it seems that ownership of an interest in a closely held entity is likely not a presently reachable economic benefit as required by the Tax Court in Hackl, especially if there are restrictions on sale of the interest...
IRS rules that the beneficiaries' withdrawal rights don't interfere with grantor trust status In PLR 200942020 (Oct. 16, 2009), the IRS addressed whether trust beneficiaries' current and hanging withdrawal rights, as well as those that previously...
Gift tax paid not brought into taxable estate of non-U.S. resident under IRC Section 2104 In CCA 20102009 (May 21, 2010), the IRS held that IRC Section 2104(b) didn't bring the amount of gift tax paid on gifts made within three years of death into...
The year 2010 may be remembered fondly by some as The Year Without Taxes because on Jan. 1, 2010, all federal estate taxes and generation-skipping transfer (GST) taxes disappeared. It was also a year with no other federal personal taxes because...
In Rev. Proc. 2010-40, Internal Revenue Bulletin 2010-46 (Nov. 15, 2010), the IRS set forth certain inflation-adjusted tax items for 2011. The inflation adjustments include the following, which take effect on Jan. 1, 2011: The annual exclusion...
Court applies cost of partition discounts to tenancy in common interests held by husband and wife in a residence The Tax Court recently upheld, but reduced, minority interest discounts on the value of two tenancy in common interests conveyed to...
Ignited by the global financial crisis in 2010, many wanted to know, Where's the money? Who owns it? How can our country get more? and Where are the super-rich moving? Here are some answers to these questions as we survey last year's activity in...
