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…

IRS May Re-Examine Estate Tax Return of Predeceased Spouse to Determine Correct DSUE Amount at Surviving Spouse’s Death

Topics: Estate planning, Estate tax, IRS, Regulation

In Estate of Sower v. Commissioner, the Tax Court held that, despite issuance of a closing letter for the predeceased spouse’s estate, the IRS retained authority to re-examine the predeceased spouse’s estate tax return for the purpose of determining the correct deceased spousal unused exclusion (DSUE) amount available to the surviving spouse’s estate.

IRS Provides Model Amendments For Defined Benefit Plan Sponsors to Offer Bifurcated Distribution Options

Topics: Defined benefit plans, IRS, Qualified Plans, Regulation

In Notice 2017-44, IRS provides model amendments for qualified defined benefit (“DB”) plan sponsors used in offering bifurcated distribution options to participants in accordance with the recently issued final regulations regarding required survivor annuity distribution options. The final regulations provide two acceptable bifurcation methods –

Feeling Charitable The IRS May Not Be When It Comes to Your Deductions – 5 Things to Know.

Topics: Charitable giving, Estate planning, IRS, Regulation

To support and incentivize charitable giving, the Internal Revenue Code (“Code”) provides an income tax deduction for contributions to qualified charities. The substantiation requirements for claiming the income tax deduction for charitable donations, however, are numerous and complex, especially for non-cash gifts.