IRS

WRN#18.03.07

Topics: Estate planning, Estate tax, IRS, Regulation

A U.S. District Court determined that the IRS did not follow applicable published guidance and therefore was not substantially justified in its position in pursuing claims for personal liability against the beneficiaries and fiduciaries for an estate tax deficiency.

In This Week’s Tax News – 18.03.02

Topics: Congress, IRS, Regulation, Tax reform, Treasury Department

By Chris Morton, Armstrong Robinson, David Hollingsworth, and Jason Martinez Friday, 2 March 2018 This week David Kautter, the acting IRS Commissioner and Assistant Secretary for Tax Policy at the Treasury Department, said tax rules for pass-throughs might not be ready until early fall. He did say an initial notice could be released earlier that…

In This Week’s Tax News – 18.02.16

Topics: Congress, IRS, Regulation, Tax reform, Treasury Department

By Chris Morton, Armstrong Robinson, David Hollingsworth, and Jason Martinez Friday, 16 February 2018 Washington has produced three significant tax laws in the last sixty days (TCJA, ACA Tax Delay, Extenders/Orphans). The outlook for additional tax legislation this year is not clear, but even the congressional tax writers would not have predicted this pace at…

WRN#18.01.06

Topics: Estate tax, IRS, Regulation, Trusts

In a recently-released series of apparently related PLRs, the IRS has again reviewed the tax consequences of incomplete gift, non-grantor (“ING”) trusts of married spouses involving the transfer of community property.

IRS Continues to Rule Favorably on ING Trusts

Topics: Estate planning, IRS, Regulation, Trusts

In PLR 201742006, the IRS examined the tax implications of two identical incomplete gift, non-grantor trusts (“ING Trusts”) created by spouses, one by the husband and one by the wife (each a “grantor”). Each ING Trust provided for payments by a Distribution Committee (of which the grantor was a member) to the trust beneficiaries, including…