The Internal Revenue Service has almost literally thrown the (Internal Revenue Code) book at family limited partnerships (FLPs), seeking to negate their validity, and thereby knock out discounts and reap higher tax payments. It has had some of its...
The intention behind incentive trusts is excellent; the rigidity of these trusts is not. It's time to ditch the inflexible incentive trusts and instead learn how to fashion a principle trust. Rather than strict rules for distributions, a principle...
As practitioners are acutely aware, the Internal Revenue Service has pursued a variety of arguments during the past decade to attack family limited partnerships (FLPs). The IRS has deployed Internal Revenue Code Sections 2036, 2701, 2702 and 2704...
During the life of a trust, its tax status may change from grantor to non-grantor, or vice versa. This may be deliberate (a powerholder relinquishes a power that caused the trust to be a grantor trust), unintentional (a change in trustee) or even...
Practitioners are well-aware that lifetime gifts are more tax-efficient than transfers at death. But during the past seven years there's been a possibility that the estate tax might be permanently repealed, so it's been out of vogue for...
Taxes are never fun but unexpected taxes are especially annoying. If a Florida resident sells a painting through a worldwide auction house, which holds the auction in New York, does he need to pay New York income taxes? If a New Hampshire resident...
As the Internal Revenue Code's Section 7520 rate dropped this year to near-record lows (down to 3.2 percent in May 2008), some estate planners began recommending that clients create long-term grantor retained annuity trusts (GRATs) to lock in a...
With the Internal Revenue Service on the verge of issuing final regulations, more than 17 professional organizations and legal commentators have taken a stand in the ongoing debate on the extent to which trusts and estates can deduct certain costs...
