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Discounts on Family Limited Partnership

The IRS is Challenging the Appropriateness of Discounts when Preparing a Valuation The current regulations, Revenue-Ruling 93-12, allow for discounts when valuing a Family Limited Partnership (FLP). The proposal is expected to potentially limit the allowed discount and consequently raise the taxable portion of the trust or estate structures. This article reviews the current requirements for FLPs, their hist ...

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IRS Grants Relief To Small Estates

(…and possibly their valuation consultant?) Rev. Proc. 2014-18 provides a simplified method for certain taxpayers to obtain an extension to elect portability under Code Sec. 2010(c)(5)(A). This method allows a widow or widower to apply a deceased spouses unused exclusion (DSUE) amount to the surviving spouse's subsequent transfers during life or at death. In these situations, the ability to file and use the ...

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IRS Wins Major Tax Shelter Case —WSJ Washington Wire

Tax Court Judges Structured Trust Advantaged Repackaged Securities” ("STARS") as Illegitimate.  Costs to BNY/Mellon May Exceed $800M. The Internal Revenue Service won a high-profile tax shelter case involving Bank of New York Mellon Corp. on Monday, in a ruling that could cost the company more than $800 million.  John D. McKinnon at the WSJ Washington Wire reports the news: ...

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Estate Taxes: Where Do We Go From Here?

This is the question addressed by Richard T. Hurt, Jeffrey M. Gad, Drew LaGrande, and Megan Costa Devault  in a paper you'll find posted in PDF form at JD Supra legal intelligence web site. The authors write for Akerman Senterfit, a law firm with expertise and focus in middle market M&A.  Here's the way things stand now: For the past several years, the federal estate tax law has provided elevated exempt ...

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Tax Law Update: Internal Revenue Service extends filing and payment deadlines for estates of decedents dying in 2010

Tax Law Update Trusts and Estates Magazine's David Handler offers a summary of significant IRS updates on a handful of important laws: Internal Revenue Service extends filing and payment deadlines for estates of decedents dying in 2010 — In Notice 2011-76 (Notice), the IRS provided relief for the estates of decedents dying in 2010 (2010 estates). The filing deadline for the Form 706, federal estate and gene ...

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