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.
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…
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…
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.
The IRS has announced that the 2017 prepayment of 2018 real property taxes will be deductible on 2017 individual income tax returns only if the tax has been assessed in 2017.
The IRS ruled that a retired employee’s receipt of excess pension payments for which collection of the overpayment was waived by the former employer was not reportable income resulting from a discharge of indebtedness.
The IRS has released compensation tables, listing amounts for both birth and Social Security retirement years, to provide employer assistance in calculating benefits under stock bonus, profit-sharing and pension plans.
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…
In Estate of Ruth M. Oberg, the decedent’s estate did not file federal or state estate tax returns until more than 4 years after her passing, despite the fact that her estate was above both the federal and New Jersey filing thresholds.
The IRS and other federal agencies have announced the following relief for the areas that were affected by Hurricane Harvey, Hurricane Irma, and Hurricane Maria: