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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.”

Important changes proposed to New York estate tax and New York income taxation of trusts, grantors and beneficiaries

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • March 5 2014

Important legislation has been introduced by New York Governor Andrew Cuomo that, if passed, would substantially change the New York estate tax

IRS addresses theft loss deductions for IRA and charitable trust investments in Ponzi schemes

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

On September 24, 2010, the IRS released a letter (the "Letter") addressing the availability of tax deductions for Ponzi scheme losses relating to assets held in individual retirement accounts ("IRAs") or similar tax-deferred investment vehicles and assets held by charitable trusts

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

$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

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

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

Court approves defined value clause for gift where excess value retained by donor

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

The U.S. Tax Court has held for the first time in Wandry v. Commissioner (Tax Court, March 26, 2012), that a donor may make a non-cash gift of a stipulated dollar amount and retain any portion of the transferred property value in excess of the stated dollar amount the donor gave away