A state law provision that enables a court to reform errors in a trust document was sufficient for IRS purposes under I.R.C. § 2041 to prevent the inclusion of the trust assets in the estate. While letter rulings are, of course, limited to their facts, this is...
Becky Farr Seidel of the Leaffer Law Group wrote a great piece recently for Bloomberg BNA’s Estates, Gifts and Trusts Journal addressing issues in terminating private foundations. Here are some salient points, and you can read the entire article here. Unlike other...
New guidance for private foundations from the IRS addresses treatment of foreign grantees. The groups may wish to treat grants to foreign grantees as qualifying distributions that satisfy the minimum distribution requirements rather than as expenditures requiring...
Under I.R.C. § 213, a deduction is available for medical services provided to a taxpayer, his/her spouse, and dependents. But this doesn’t mean that all IVF procedures and other pregnancy-related costs are covered simply because the taxpayer’s dependent...
Trump’s new tax proposal makes some changes that could affect your estate planning. Both the estate and generation-skipping taxes get the boot. What about stepped up basis under I.R.C. § 1014? R.C. § 1014 provides that, for most property, a decedent’s...
Practitioners had been worried that the Section 2704 proposed regulations were going to affect minority discount valuations for gift and estate tax purposes. Worry no more.The U.S. Department of the Treasury’s Second Report to the President on Identifying and...