Abstracts » Law

Disclosure sets a time limit on IRS gift revaluation

Article Abstract:

The introduction of the Taxpayer Relief Act of 1997 and IRS Restructuring and Reform Act of 1998 is part of a legislative trend intended to establish the values of gifts before the donor's death. The former obligates the IRS to examine the values of gifts given after Aug 05 1997 within three years following their proper disclosure. The latter authorizes the Service to set a permanent value for the gift if the donor does not contest it within the limitations period. These tax law changes are generally advantageous for the beneficiaries of taxpayers who will die after Apr 15, 2001, but they present new challenges for tax practitioners especially if the property given by the donor as a gift is difficult to value. Tax practice tips are discussed.

Tax Law, Public Finance Activities, Tax Management, Estate Planning, Methods, Planning, Tax accounting, Tax planning, Valuation, Gifts, Gift tax

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Save transfer taxes with family limited partnerships

Article Abstract:

The author discusses the US Tax Court's decisions in the Estates of Strangi and Knight, which dismissed the IRS' challenges to family limited partnerships (FLPs), and the uses of FLPs in estate planning.

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Avoid tripping on family limited partnership trap

Article Abstract:

The authors discuss the IRS' use of IRC section 2036(b) to negate estate tax benefits families seek from family limited partnerships when they transfer appreciating business interests.

Laws, regulations and rules, Estate tax, Estate taxes

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