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Second Circuit vacates Tax Court's determination on inclusion of transferred interest in real estate under IRC Section 2036 In Estate of Stewart v. Comm'r, No. 07-5370 (2d. Cir. Aug. 9, 2010), the majority of the U.S. Court of Appeals for the...
Sixth Circuit upholds constructive addition generation-skipping transfer (GST) tax regulations In Estate of Timken, 105 A.F.T.R. 2010-1347 (April 2, 2010), the U.S. Court of Appeals for the Sixth Circuit upheld the constructive addition...
IRS ignores trust amendment designed to create designated beneficiary PLR 201021038 (May 28, 2010) shows the importance of careful drafting for a trust designated as the beneficiary of a retirement plan. In this ruling, a husband named the bypass...
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...
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...
Legg Mason has tapped Peter Nachtwey as its new chief financial officer, replacing Terrence Murphy, who has served as interim CFO since July. Nachtwey joins from The Carlyle Group, where he served in a similar role at the alternative investment...
