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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.”

Gift of IRS to charity does not result in income to decedent’s estate

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

A decedent had set up a trust that provided for certain specific gifts to be made upon his death and then for the residual amount remaining to be transferred to a charity

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

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

New Internal Revenue Code Section 457a to end deferral of fee income from offshore funds

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • December 20 2008

Using a foreign corporation or other entity to manage an offshore investment fund created a popular tax deferral opportunity for any United States individual managers who were employed by the foreign entity

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

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

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