The e-file PIN retrieval tool was taken offline in June, following a suspicious uptick in attempts to use it, IRS Commissioner Koskinen reported at a security meeting in June. Taxpayers can no longer sign returns that they file online with an electronic filing personal identification number. The IRS is still trying to determine how many…
Month: August 2016
Proposed Regulations
In June the ABA’s Section of Real Property, Trust and Estate Law sent its comments to the IRS on the Proposed Regulations on consistent basis. A wide variety of technical improvements were suggested. Four substantive changes also were included: Reporting requirements should cease when an asset has been included in a subsequent estate. Pecuniary bequests…
A stand-alone tax bill in September?
That was the hint dropped by Ways and Means Committee Chair Kevin Brady (R-Texas) in a July press conference, referring to the series of hearings held earlier this year. No specific legislation was identified. The key point is that Brady will be overseeing a new process for pushing tax bills through. “We are not bringing…
A transfer to an in-law may not be presumed to be a gift.
Cohen v. Raymond, 128 A.3d 1072 (N.H. 2016) Cohen got along famously with his son-in-law Raymond, who went to work in his father-in-law’s scrap metal company. Raymond became one of Cohen’s most valuable assistants. In 2006, Cohen sold the company. He and Raymond each received three-year employment contracts. However, they were not very happy working…
Extension granted for proving that a surviving spouse has become a U.S. citizen.
Private Letter Ruling 201628011 Decedent’s surviving spouse was not a U.S. citizen, so to secure the marital deduction from the federal estate tax his will created a Qualified Domestic Trust (QDOT) for her lifetime benefit. Some time later, the surviving spouse became a U.S. citizen, but she didn’t mention this development to the QDOT trustee.…
Defined value clauses and sales to grantor trusts
Estate planners have been watching the Woebling cases because they included two somewhat aggressive estate planning strategies: use of a defined value formula gift to limit gift tax exposure, and the sale of stock to a grantor trust in exchange for a promissory note. Unfortunately, the resolution of the cases earlier this year will not…
529 Plans: Advanced Questions
During the presidential primary campaigns, the cost of higher education and the burden of education loans upon recent graduates was been a recurring theme. Families with higher incomes have addressed these costs by contributing to tax-preferred savings vehicles, such as the 529 plan (named for a section of the tax code). In his 2015 State…