The Presumption of Innocence Podcast: Episode 21 - Conservation Easement Donations: Tax Shelter or Charitable Contribution Deduction?
Jones Day Presents: Strategies for Dealing with IRS Appeals: When Exam Attends the Appeals Conference
Jones Day Presents: Strategies for Dealing with the IRS: Going to Court
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Appeals Office
The May 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.00%, which is the same as the April 2025 Section 7520 rate...more
When purchasing an expensive engagement ring, one would not seek the expertise of a real estate agent. Similarly, when an estate requires an appraisal, it is crucial to engage the appropriate expert for high value personal...more
A recent Tax Court order highlights the gift and estate planning opportunities afforded when a senior family member makes loans to other family members. In Galli v. Commissioner, Docket Nos. 7003-20 and 7005-20, the Court had...more
A parent will sometimes transfer money to a child to enable the child to make an investment that the child could not otherwise make on their own. For example, the child may have identified an attractive business opportunity...more
If you’re like most people, an important goal of estate planning is to provide financial assistance to your children or other loved ones, ideally at the lowest possible tax cost. There are many strategies for achieving this...more
Through the years, the US Tax Court has provided significant clarification on the gift tax consequences of terminating qualified terminable interest property (QTIP) trusts. Two new cases in 2024, Estate of Sally J. Anenberg...more
Short Summary. Decedent was a wealthy lawyer and investor. During the last few years of his life, decedent paid significant sums to one of his daughters, one of his stepdaughters, and multiple women with whom he was either...more
Tax the Rich? The President’s plan for a tax regime that would ensure the rich pay their “fair share” of the cost of implementing his programs has come one step closer to being realized . . . maybe . . . well, sort of ....more
This program is the first of Freeman Law’s multi-class course designed to prepare CPAs and Enrolled Agents for the Tax Court’s admissions examination. Participants will receive an overview of the Tax Court and will learn...more
Determining the “fair market value” of assets for Gift and Estate Tax purposes can be a daunting task depending upon the nature of the asset to be valued. Valuing certain types of assets, such as real estate or tangible...more
Woe to Us? We live in strange times. The coronavirus pandemic hit the United States hard, the scientific community fears a second round later this year, and there have been wildly differing estimates over when an...more
In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more
July Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The July § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and...more
In Steinberg v. Commissioner, 145 T.C. No. 7 (September 16, 2015), an 89 year old donor made a $109 million taxable gift to her four daughters. The gift was made after the donor and the daughters entered into a gifting...more
The IRS and executors have settled two cases in the United States Tax Court involving members of the Woelbing family, who own Carma Laboratories, Inc., of Franklin, Wisconsin, the maker of Carmex skin care products, and a...more
February Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The February § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more
In a recent taxpayer victory, the Tax Court found in favor of the taxpayer with respect to three hotly contested gift and estate planning issues involving family limited liability companies. The Tax Court decided the case of...more
Lifetime giving is a smart strategy to reduce a taxable estate, but the gift tax rate of 40% is steep. If one has used up his or her $5.43 million gift and estate tax exemption and would like to potentially reduce his or her...more
A number of recent cases highlight particular issues in valuation of assets for purposes of the estate and gift tax. On July 6, 2015, the Internal Revenue Service settled Estate of Davidson v. Commissioner, T.C. Docket No....more