Planning for an unlimited revaluation period on prior gifts

Article Abstract:

Estate and gift tax planners should note that IRC section 2504(c) does not bar revaluation of an inter vivos gift after the three-year limitation period if the gift did not result in a gift tax assessment or payment. Inter vivos gifts have certain tax planning advantages, but taxpayers should reconsider gifts of difficult-to-value property such as mineral rights, land and closely held stock in light of potential revaluation. Revaluation for gift tax purposes can result in increased estate tax liabilities.

Laws, regulations and rules, Gift tax, Limitation of actions (Taxation), Statute of limitations (Taxation)

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Tax malpractice in the estate and gift tax areas

Article Abstract:

Issues surrounding claims of tax professionals' malpractice in the area of estate and gift taxes are discussed. Various situations which may lead to malpractice are the focus of the article which includes an examination of the valuation of damages.

Cases, Attorneys, Lawyers, Accountants, Estate planning, Malpractice, Legal malpractice

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Interim tactics in transfer tax planning

Article Abstract:

The authors discuss transfer tax planning following Pres Bill Clinton's veto of the Death Tax Elimination Act of 2000.

Management, Tax planning

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