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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.”

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

$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

New California law may require individual trustees of trusts to be licensed

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

The California Professional Fiduciaries Act becomes effective on January 1, 2009

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

California graduated probate filing fee held unconstitutional

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

The State of California imposed a graduated probate filing fee structure based on the value of the probate estate

Tax court denies business expense deduction for costs incurred consulting for businesses partially owned by the taxpayer

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

The recent Tax Court case of Estate of Roger Strangeland v. Commissioner illustrates a problem faced by families that have interests in numerous businesses and investments

Review estate plans in light of $5 million exemption becoming permanent

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • January 24 2013

When the estate tax exemption first reached $3.5 million in 2009, we cautioned clients to review their estate plans to be sure the significantly