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Private letter ruling suggests that assets held in a grantor trust and not included in grantor’s estate may nevertheless receive a basis increase

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • May 20 2013

In PLR 201245006, the IRS addressed a question that has been puzzling tax advisors for years. A person who was not a citizen or resident of the

Two taxpayers lose income tax deductions for spousal support payments

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • September 5 2013

Two recent Tax Court cases serve as a reminder that the income tax deduction for the payment of spousal support is subject to some very specific rules

New York estate and trust tax changes: the good, the bad and the ugly

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • April 10 2014

As we noted in our recent client alert, New York Governor Andrew Cuomo announced in January that he would introduce legislation intended to reduce

IRS moves against incomplete gift strategy

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • April 24 2012

For a long time, a popular tax-planning strategy has involved the use of an “incomplete gift.”

IRS issues ruling favorable to “intentionally defective grantor trusts”

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • August 26 2008

The so-called “Intentionally Defective Grantor Trust” (“IDGT”) has become a very popular estate planning technique

Estate prevails in dispute over valuation of interest in a closely held business

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • August 2 2011

The taxpayer prevailed in a significant estate tax valuation case in Estate of Louise Paxton Gallagher (June 28, 2011

Fifth Circuit reverses Tax Court on amount of discount allowed in determining estate tax value of works of art

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • December 23 2014

We previously reported on the Tax Court case Elkins v. Commissioner (March 11, 2013) (Vol. 8, No. 2, May 2013). At issue was the value, for estate

Tax Court allows some discount in valuing fractional interests in works of art

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • May 20 2013

In Elkins v. Commissioner (Tax Court, March 11, 2013), the decedent had owned an art collection consisting of 64 pieces, some of which were paintings

Recent case points out even more risks of serving as fiduciary

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • August 16 2012

By now most people are aware that significant legal and economic exposure goes along with serving as a personal representative or trustee for a close friend or family member

2010: a good year to die?

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • February 26 2010

For high-net-worth individuals and their advisors, January 1, 2010 marked more than just the New Year