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The taxpayer victory in the Christiansen appeal is a gift for charities because it effectively throws open the door to charitable lid planning. The U.S. Court of Appeals for the Eighth Circuit has given charities, taxpayers and estate planners...
Estate and gift tax valuation positions associated with family limited partnerships (FLPs) often are challenged by the Internal Revenue Service and somewhat unpredictably adjudicated by the courts. But in the last two years, taxpayers have won...
Gift restrictions have always been a component of charitable gift planning. In 1643, Lady Anne Radcliffe Mowlson created the first scholarship at Harvard College. In 1887, Josephine Louise Le Monnier Newcomb contributed $100,000 to establish the...
Traditional buy-sell agreements can't always solve all problems dealing with death, retirement, withdrawal and disability without creating difficulties with income tax, estate tax, step-up in basis, alternate minimum tax (AMT) and transfer for...
Few Type III supporting organizations (SOs) are likely to be overjoyed by the new proposed regulations that could soon be governing them. Yet, these anxiously awaited proposed regs1 are significantly better than we might have expected, given some...
In what kind of Alice in Wonderland world might clients be better off destroying good things like charitable remainder trusts (CRTs)? Answer: in the down-the-rabbit-hole world where we find ourselves these days. Here are three good reasons why we...
If Ponzi schemer Bernard Madoff serves no other purpose, he's a stark reminder that anyone acting in a fiduciary capacity must maintain high standards of ethical conduct in all dealings with customers and clients. In fact, it could be argued that...
Recent declines in the real estate and credit markets provide a unique opportunity in valuations of promissory notes. At first blush, the fair market value (FMV) of promissory notes, secured or unsecured, appears to be easily determined. Treasury...