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Results: 1-10 of 106

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.”


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


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


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 streamlines Offshore Voluntary Disclosure Program
  • Loeb & Loeb LLP
  • USA
  • September 29 2014

On June 18, 2014, the IRS announced new Streamlined Filing Compliance Procedures (Streamlined Programs) and changes to the existing Offshore


Executors must be careful when requesting an extension of time to pay estate tax
  • Loeb & Loeb LLP
  • 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


Estate denied deduction for settlement payment to caregiver
  • Loeb & Loeb LLP
  • USA
  • January 24 2013

In Estate of Sylvia E. Bates (2012), the Tax Court rejected an estate's attempt to deduct a settlement payment to the decedent's caregiver as an


More mixed results in litigation of family limited partnership cases
  • Loeb & Loeb LLP
  • USA
  • September 14 2009

The enormous tax dollars at stake in connection with valuation discounts for estate and gift tax purposes is evidenced by the never ending stream of family limited partnership cases