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...
In an effort to provide uniformity and certainty in the valuation of claims for estate tax purposes, the Department of Treasury issued proposed regulations on April 23, 2007, to clarify that post-death events are to be considered in valuing...
The mere words asset protection make some lawyers wince.1 They think asset protection is dirty and those engaged in it are the ambulance chasers of the estate-planning bar. Of course, we all should turn our noses up at lawyers who tightrope walk...
Think back to a time long, long ago, before the adequate disclosure rules of 1997, before the changes in the generation-skipping transfer (GST) tax deemed allocation rules of 2001. It was a simpler time. At tax preparation firms all across the...
For the first time, the U.S. Supreme Court has asserted that it not only believes in the taxpayer rights enunciated more than 70 years ago by Judge Learned Hand but also that the court embraces this position even more firmly than the eminent judge...
Estate planners can learn from financial planners. For years, financial planners have used hedging techniques to reduce risk or to guarantee a desired outcome. This is done by entering into a transaction that moves in the opposite direction as the...
The Internal Revenue Service released Notice 2008-13 on Jan. 2, 2008, to provide interim guidance on the application of tax preparer return penalties put in place by The Small Business and Work Opportunity Act of 2007.
Let's look at the recent past, the better to see what the future of the estate tax will be in the years 2009, 2010, 2011 and beyond. My predictions about what we can expect are based on the Nov. 14, 2007 Senate Finance Committee (SFC) hearing...
Low Internal Revenue Service discount rates make this an ideal time to use grantor retained annuity trusts (GRATs), as it's easier now to get over the hurdle that makes the GRAT effective. Still, the fact that one has to beat the IRS discount rate...
