Tag Archives: Tax

IRS Temporarily Halts PLRs on Certain GST Tax Issues

On March 3, 2017, Melissa C. Liquerman, a branch chief for the IRS Office of Chief Counsel, announced at the Federal Bar Association Tax Law Conference that, due to “budget cuts and prolonged strain on agency resources,” the IRS is temporarily suspending the issuance of private letter rulings (PLRs) relating to certain generation-skipping transfer (GST) … Continue Reading

California Court of Appeal Holds Passive LLC Interest Does Not Create Nexus

A non-California corporation’s only connection with California was its passive minority interest in a limited liability company (LLC) that was doing business in California. The California Court of Appeal held that this limited connection was not sufficient to subject the out of state corporation to California’s Corporation Franchise Tax. All taxpayers that have filed and … Continue Reading

The Unwanted IRS Time Machine – Is Your Gift Tax Return Actually Done?

Taxpayers may assume that once a gift tax return is filed, they can sit back and avoid worrying about the IRS making adjustments once the general three-year statute of limitations has passed. But the IRS has a powerful “rewind-the-clock” tool that taxpayers may inadvertently trigger if they aren’t careful when preparing any filed gift tax … Continue Reading

2017 Federal Tax Inflation Adjustments

Each year, the IRS makes inflation adjustments to numerous thresholds, exemptions, exclusions, and other amounts that affect various tax calculations under the Internal Revenue Code. For example, annual inflation adjustments apply to the standard deductions available to taxpayers for income tax purposes, the filing thresholds for each income tax bracket, the amount available for annual … Continue Reading

IRS Defines ‘Spouse,’ ‘Husband,’ ‘Wife,’ and ‘Marriage’ for Tax Purposes

The IRS recently issued final regulations, effective as of Sept. 2, 2016, providing gender-neutral definitions of “spouse,” “husband,” and “wife,” and clarifying the definition of “marriage” for federal income, transfer, and employment tax purposes. Under the new final regulation section 301.7701-18(c), a marriage (same-sex or opposite-sex) will be recognized for federal tax purposes if it is … Continue Reading

Jon Forster and Scott Meza Participated in the GT co-hosted Presentation ‘Preparing For An Exit: What CEOs and CFOs Need to Know (and Do)’

Northern Virginia Greenberg Traurig Shareholders, Jon Forster and Scott Meza, participated as panelists in the program titled, “Preparing For An Exit: What CEOs and CFOs Need to Know (and Do)” on Nov. 2, 2016, in McLean, VA. Greenberg Traurig was a co-sponsor of this program. The program focused on specific elements of a successful M&A … Continue Reading

Bill to Simplify State Tax Withholding on Mobile Workers Passes House

A bill that would simplify state income tax compliance for employers when they send employees on temporary assignment to another state passed the House on Sept. 21. Many state government interests oppose the bill, so its future in the Senate is uncertain. Employers face a major state tax compliance headache when they send an employee on … Continue Reading

Treasury Department Issues Proposed Regulations That Will Dramatically Reduce Valuation Discounts

On Aug. 2, 2016, the Treasury Department issued proposed regulations under Section 2704 of the Internal Revenue Code that, if finalized in their present form, would substantially alter the valuation of transfers of interests in family-controlled entities (including corporations, partnerships, and LLCs) for estate, gift and generation-skipping transfer tax purposes. To read the full GT … Continue Reading

Portability of the Estate and Gift Tax Exclusion – How Does it Work?

Portability refers to the ability of a surviving spouse, to make use of a deceased spouse’s unused estate tax exclusion amount (DSUE amount).  Portability was intended to simplify estate planning for married couples by eliminating the need for a bypass trust.  However, in order to preserve the DSUE amount the surviving spouse must comply with … Continue Reading

Bill to Bar Air Excise Tax on Aircraft Management Fees Clears House Ways and Means Committee

A bill that would exempt aircraft management fees from the federal air transportation excise tax is advancing in the House — good news for aircraft owners who use a leasing company structure to save on state sales tax when purchasing aircraft. The bill (H.R. 3608) clarifies that fees paid to an aircraft services company to … Continue Reading

When a Fiduciary is Personally Liable for Unpaid Taxes

Although many people name family and friends as trustees or personal representatives in their legacy plan, it’s probably safe to assume that the people being appointed don’t have an understanding of the high level of responsibility inherent in carrying out their fiduciary duties.  One of the greatest fiduciary responsibilities is payment of a trust’s or … Continue Reading

Greenberg Traurig Webinar – What’s Trending?

Greenberg Traurig Tax & Business Group attorneys, Jonathan Forster and Todd Steinberg, hosted a webinar on important recent developments in the estate planning marketplace.  Forster and Steinberg reviewed the latest on the Morrissette case (the very first reported generational split dollar tax court case), the settlement of Woelbing (the latest seminal case involving installment sales to grantor trusts), … Continue Reading

GT Alert: Excise Tax Refund Opportunity for Foreign Reinsurers for Retrocession Policies

Greenberg Traurig’s Tax Practice recently published an alert discussing the excise tax refund opportunities for foreign reinsurers for retrocession policies.  The IRS has decided to back off its position that the one percent excise tax is due on a policy of reinsurance where a foreign reinsurer reinsures a policy of reinsurance issued by another foreign reinsurer … Continue Reading
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