The U.S. Internal Revenue Service has just announced that it will end the Offshore Voluntary Disclosure Program (“OVDP”) on 28 September 2018. ...more
Remember all that time and energy you put into figuring out what the proposed regulations under Section 2704 were all about? Well, you’re going to want to try to find a way to get that back. The proposed regulations, the...more
Chapter 14 of the Internal Revenue Code consists of four Code Sections (Sections 2701 – 2704) designed to close valuation loopholes. Prior to Congress’s enactment of Chapter 14 in 1990, estate planners had a host of tools...more
8/31/2016
/ Business Entities ,
Estate Planning ,
Estate Tax ,
Family Businesses ,
Gift Tax ,
IRC Section 2704 ,
IRS ,
Liquidation ,
Proposed Regulation ,
Stocks ,
Transfer of Assets ,
Transfer Taxes ,
Valuation ,
Voting Shares
Open the estate, marshal the decedent’s assets, file the estate tax return, pay estate taxes and debts, receive the estate tax closing letter from the IRS, and distribute the remaining assets. While overly simplistic, this...more
On Wednesday, 26 June 2013, the US Supreme Court ruled that Section 3 of the Defense of Marriage Act (“DOMA”), which limits the definition of “marriage” to “a legal union between one man and one woman as husband and wife” and...more
6/29/2013
/ Civil Unions ,
Discrimination ,
DOMA ,
Equal Protection ,
Estate Planning ,
Estate Tax ,
EU ,
Gift Tax ,
Gift-Tax Exemption ,
Income Taxes ,
IRS ,
Same-Sex Marriage ,
SCOTUS ,
Sexual Orientation Discrimination ,
Surviving Spouse ,
US v Windsor
In the wake of a series of scandals involving U.S. taxpayers sheltering their assets from the reach of the U.S. Internal Revenue Service (IRS), Congress enacted the Foreign Account Tax Compliance Act (FATCA) on 18 March 2010...more