On Feb. 15, 2022, the IRS announced revisions to Form 14457, the Voluntary Disclosure Practice Preclearance Request and Application. The longstanding Voluntary Disclosure Practice is a way for taxpayers who
Continue Reading IRS Announces Revisions to the Application Form for Voluntary Disclosures with New Provisions for Cryptocurrency, Employment Tax, and Estate, Gift and Generation-Skipping Transfer Tax
IRS announces the 2019 inflation-adjusted figures for gift and estate tax exemption amounts.
The federal gift, estate, and GST exemption amount ( the exemption amount) is the total amount
Continue Reading Federal Individual Gift, Estate, and GST Exemptions Increase to $11.4 Million in 2019
The Internal Revenue Service (IRS) publishes a monthly update to the applicable federal rates (AFRs) and 7520 rates.
Planning professionals and their clients should take note of fluctuations in these rates and be mindful of planning opportunities that come with rate changes.
The AFR is calculated by the IRS under Section 1274(d) of the Internal Revenue Code (the Code) and is used for many purposes. One of its most common applications is to establish the minimum interest rate that can be charged on an intra-family loan without income or gift tax consequences. These “safe harbor rates” are dependent upon two factors: (i) the term of the loan and (ii) the frequency of compounding of interest.
Continue Reading IRS Announces October 2017 Applicable Federal Rates and 7520 Rates
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
Continue Reading IRS Temporarily Halts PLRs on Certain GST Tax Issues
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 a complex set of rules, including filing a federal estate tax return for the decedent even though one would not otherwise be required. Portability is not a substitute for traditional estate planning, particularly for high net worth individuals. However, it may prevent an otherwise unused DSUE amount from being completely lost.
Continue Reading Portability of the Estate and Gift Tax Exclusion – How Does it Work?