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Federal Taxation

  • Recent Court Decision Highlights the Split in Authority Concerning the Estate Tax Treatment of Life Insurance under a Buy-Sell Agreement

    By:
    Kevin Matz, Esq., CPA, LLM
    |
    Oct 1, 2023
    In Connelly v. United States, No. 21-3683 (8th Cir. 2023), the United States Court of Appeals for the Eighth Circuit, on the taxpayer’s appeal from an order granting summary judgment in favor of the IRS by the United States District Court for the Eastern District of Missouri, considered(i) whether a buy-sell agreement was able to fix the value of the decedent’s corporate shares for estate tax purposes (it was not), and (ii) whether life insurance proceeds payable to the corporation to help fund a corporate redemption of shares needed to be considered in determining the fair market value of the corporate shares for federal estate tax purposes.

  • Recent Tax Court Case Contains Detailed Discussion of Gift Tax Adequate Disclosure Requirements

    By:
    Kevin Matz, Esq., CPA, LLM
    |
    Sep 1, 2023

    Schlapfer v. Commissioner, T.C. Memo. 2023-65 (U.S. Tax Court May 22, 2023), is the first reported case to contain a detailed discussion of the adequate disclosure requirements under the gift tax adequate disclosure regulations that are set forth in Treas. Reg. Sec. 301.6501(c)-1(f).

     

  • Recent IRS Challenges to Grantor Retained Annuity Trusts (GRATs)

    By:
    Kevin Matz, Esq., CPA, LLM
    |
    Aug 1, 2023

    There are two separate significant IRS challenges to grantor retained annuity trusts (GRATs) in the context of ongoing merger negotiations that have garnered considerable attention going back to 2019. 

  • Impact of SECURE 2.0 on Planning for Trusts

    By:
    Steven. B. Gorin CPA, Esq., CGMA
    |
    Aug 1, 2023

    The last two articles the author wrote, Dealing with Proposed Regs under the SECURE Act and Strategy Under the SECURE Act, examined certain strategic issues that CPAs may need to explain to their clients. This article assumes the reader knows those concepts as a base and complements those ideas with planning for long-term second marriages and for trying to minimize fiduciary income tax on IRAs held in trust without necessarily getting IRA distributions out of trust.   

  • Code Section 754: Allocating Gain Where it Belongs

    By:
    Dean L. Surkin, JD, LLM
    |
    May 1, 2023
    The genesis of Code Section 754 stretches back to the first third of the 20th century, as the IRS tried to combat tax avoidance through income shifting from higher-bracket taxpayers to lower-bracket taxpayers.

  • Nothing to Fear but Fear Itself: Planning in the Current Environment

    By:
    Carl Fiore, JD, LLM
    |
    May 1, 2023
    As the calendar turns to 2023, taxpayers and their advisors face an uncertain future. Given a divided government for at least the next two years, it is not the usual suspect of potential legislation and sweeping tax changes that fuels this uncertainty. Instead, a declining market, the potential for recession looming, and increasing interest rates has left many taxpayers in a general malaise heading into the new year.

  • Final Subpart F Regulations and Domestic Partnership Tax Reporting

    By:
    Sean Dokko, JD, LLM (taxation) and Suzy Lee, CPA 1
    |
    May 1, 2023
    On January 25, 2022, the Department of the Treasury and the Internal Revenue Service (collectively, “the Treasury”) published in the Federal Register final regulations (T.D. 9960) which generally treat a domestic partnership2 as an aggregate of its partners for purposes of determining whether, and to what extent, its partners have Subpart F inclusions (the final Subpart F Regulations).3 Application of the final Subpart F Regulations can affect a domestic partnership’s Schedules K-1, K-2 and K-3 reporting.
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