Introduction Practitioners are still grappling with the intricacies and complexities of the Proposed 2704 Regulations. But it is vital to start addressing some of the long existing tax doctrines […]
Introduction On August 4, the Treasury Department issued Proposed Regulations that restrict or eliminate valuation discounts for family-owned businesses under IRC Sec. 2704. The Proposed Regulations will be the […]
Introduction OK stop holding your breath! The long awaited discount Regs were just issued. 26 CFR Part 25 [REG-163113-02] RIN 1545-BB71. They will be published in the Federal Register […]
► Remainder Interest in Residence and Farms: Generally, a charitable deduction is not permitted for charitable gifts of less than a donor’s entire interest in property. IRC Sec. 170(a)(3). […]
Pre-Election Estate Tax Proposals – Why Care Are major estate tax law changes in the offing? Perhaps, but my Ouija board smoked when I asked the question. So baring […]
New Rules The process of determining the value of estate assets, and filing the required estate tax return, have been made even more complicated by law changes that […]
Background When a benefactor, say a parent, loans an heir, say a child, funds, historically that transfer would have generally been desirable to treat as a loan. If the […]
Trusts are ubiquitous in estate, tax, financial and asset protection planning. Everyone tends to be pretty focused on the decision process involved in creating a trust. However, clients and advisors […]