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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

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.”

Co-op shareholder cannot deduct amount of assessment to repair damage

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

A recent Tax Court case serves to point up one of the distinctions between owning your home outright and owning your home through the ownership of shares in a residential cooperative corporation (“coop”

Expatriating to avoid taxes has become even less attractive

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

Each year, a number of Americans give up their United States citizenship and move to a country that imposes fewer taxes

IRS clarifies application of passive loss rules to trusts

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • November 21 2007

Under IRC 469, losses incurred by individuals (including estates and trusts) in connection with passive activities are deductible only to the extent that the taxpayer also has income from passive activities

Uncharted waters the “repeal” of the estate tax and your estate planning

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • January 29 2010

Effective January 1, 2010, the federal estate tax and generation-skipping transfer tax have been repealed, and basis adjustments applicable to a decedent’s assets have been sharply curtailed

Court of Appeals reverses part of IRS victory in gift with retained interest case

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • December 1 2010

Gifts that you make during your lifetime may be subject to a gift tax, but they are not included as a part of your estate for estate tax purposes if you really part with the property that is the subject of the gift

$5,120,000 lifetime gift tax exemption expiring soon

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

To understand the impending deadline, a little history is in order

More family limited partnerships in court

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

Several recent cases have addressed tax issues related to family limited partnerships or limited liability companies