Planning for post-death expenses in light of Hubert

Article Abstract:

The US Supreme Court's decision in Estate of Hubert suggests some tax planning options regarding the allocation of estate administration expenses against post-death income. Allocation of expenses should be considered when an income tax deduction can be obtained without reducing estate tax deductions, when allocation can increase bypass trust funding and when a specific bequest will trigger estate tax liability. The Court established a test in the middle ground between the IRS' position and the argument that permissible allocation with not reduce marital and charitable deductions.

Interview, Decedents' estates, Professional fees, Executors and administrators, Executors, Akers, Steve R.

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International R&D and technology transfer arrangements

Article Abstract:

Basic models for structuring research and development (R&D) funding and technology transfer arrangements include the license/royalty, contract research, and cost sharing models, or combined license/royalty contract research or cost sharing models. These arrangements should be organized to make maximum use of the R&D expenditure deduction. Cost-sharing arrangements have become widely used because of fears about excessive taxation of technology intangibles income.

International aspects, Industrial research, International business enterprises, Multinational corporations, Technology transfer, Research and development tax credit, international

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