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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
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- USA
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- 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
IRS moves against incomplete gift strategy
- Loeb & Loeb LLP
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- USA
- -
- April 24 2012
For a long time, a popular tax-planning strategy has involved the use of an “incomplete gift.”
Tax Court allows some discount in valuing fractional interests in works of art
- Loeb & Loeb LLP
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- USA
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- 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
President’s fiscal year 2014 budget contains numerous tax provisions
- Loeb & Loeb LLP
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- USA
- -
- May 20 2013
President Barack Obama released his proposed budget for the government's fiscal year 2014 on April 10, 2013, and, not surprisingly, the budget
IRS clarifies application of passive loss rules to trusts
- Loeb & Loeb LLP
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- 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
Tax court denies business expense deduction for costs incurred consulting for businesses partially owned by the taxpayer
- Loeb & Loeb LLP
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- USA
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- 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
Discount for fractional interest in art limited to 5
- Loeb & Loeb LLP
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- USA
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- May 19 2009
In Stone v. United States (March, 2009) the United States Court of Appeals for the Ninth Circuit (which includes California) upheld an earlier decision by the District Court that an estate was allowed a fractional interest discount of only 5 on the 50 interest it owned in a collection of nineteen paintings
Understanding changes to the federal estate tax law: an in-depth look at the challenges of the 2010 estate tax repeal and consequences for the future
- Loeb & Loeb LLP
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- USA
- -
- March 31 2010
Certain monumental changes have been made to the federal estate tax law in recent times
Executors must be careful when requesting an extension of time to pay estate tax
- Loeb & Loeb LLP
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- USA
- -
- April 6 2011
The federal estate return and the payment of any estate tax are both due nine months after the date of a decedent's death
Foreign bank account reporting update final FBAR Regulations and new 2011 offshore account voluntary disclosure program
- Loeb & Loeb LLP
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- USA
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- April 6 2011
Foreign bank account reports (FBARs) for 2010 are due on June 30, 2011 (and no extension is available
