Tag Archives: IRS

IRS Announces December 2017 Applicable Federal Rates and 7520 Rates

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 … Continue Reading

Federal Estate Tax Exemption Increases to $11.2 Million in 2018 (For a Married Couple)

The federal estate (and gift) tax exemption amount (exemption amount) is the total amount that an individual may transfer during life, or at death, without incurring gift, estate, or generation-skipping transfer tax on the value of the transferred assets.  This amount is adjusted annually for inflation, meaning that even if you exhaust your exemption amount … Continue Reading

IRS Provides Tax Relief for Victims of Hurricanes Harvey, Irma, and Maria

The IRS has announced that “affected taxpayers” in areas of Florida, Georgia, Puerto Rico, Texas, and the U.S. Virgin Islands designated as “covered disaster areas” are eligible for the postponement of time to file returns, pay taxes, and perform other time-sensitive acts. Taxpayers in the categories below constitute “affected taxpayers”: Individuals who live, and businesses … Continue Reading

IRS Announces October 2017 Applicable Federal Rates and 7520 Rates

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 … Continue Reading

Greenberg Traurig’s Seth Entin Quoted in Accounting Today on Recent IRS Ruling

Greenberg Traurig Shareholder Seth Entin was recently quoted in Accounting Today for an article on a recent IRS Ruling in the U.S. Tax Court. In July, the U.S. Tax Court rejected a long-standing Internal Revenue Service ruling and held that when a non-U.S. person sells an interest in a partnership or is completely redeemed from a … Continue Reading

IRS Announces August 2017 Applicable Federal Rates and 7520 Rates

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 … Continue Reading

IRS Announces June 2017 Applicable Federal Rates and 7520 Rates

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 … Continue Reading

IRS Announces May 2017 Applicable Federal Rates and 7520 Rates

The Internal Revenue Service (IRS) publishes a monthly update to the applicable federal rates (AFRs) and 7520 rates. The May 2017 rates generally reflect a slight decrease from the April 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 … Continue Reading

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

IRS Announces Slight Increase for April 2017 Applicable Federal Rates and 7520 Rates

The Internal Revenue Service (IRS) publishes a monthly update to the applicable federal rates (AFRs) and 7520 rates. The April 2017 rates reflect a slight increase from the March 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 … Continue Reading

IRS Announces Slight Decrease for March 2017 Applicable Federal Rates and 7520 Rates

The Internal Revenue Service (IRS) publishes a monthly update to the applicable federal rates (AFRs) and 7520 rates. The March 2017 rates reflect a slight decrease from February’s rates. Planning professionals and their clients should take note of fluctuations in these rates and be mindful of planning opportunities that may come with rate changes. The … 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

AICPA Suggests Adequate Disclosure Reference for Section 2704 Proposed Regulations

The American Institute of Certified Public Accountants (AICPA) recently published recommendations for a disclosure statement to be included on a U.S. Gift (and Generation-Skipping Transfer) Tax Return (IRS Form 709) disclosing the transfer of an interest in a family partnership or family controlled entity made on the same date or after the issuance of the … Continue Reading

IRS Announces Increase for February 2017 Applicable Federal Rates and 7520 Rates

The Internal Revenue Service (IRS) publishes a monthly update to the applicable federal rates (AFRs) and 7520 rates. The February 2017 rates reflect a slight increase over January’s 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 … 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

Estate Tax Exemption Nears $11 Million (For a Married Couple)

The estate (and gift) tax exemption amount (exemption amount) is the total amount that an individual may transfer during life, or at death, without incurring gift or estate tax on the value of the gifted assets.  This amount is adjusted annually for inflation, meaning that even if you exhaust your exemption amount by making substantial … Continue Reading

Does Fraudulent Conduct by Someone Else Extend the Statute of Limitations Permitting the IRS to Pursue the Taxpayer?

A fraudulent tax return is bad news for a taxpayer. Normally, the IRS has a limited period of time (3 years) to audit a taxpayer’s return.  The existence (or allegation) of fraud, however, gives the IRS an unlimited amount of time to make an assessment of tax liability.  But more importantly, taxpayers may be surprised … 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

GT’s Quick Guide to Section 338(h)(10) Elections

Section 338(h)(10) of the Internal Revenue Code can provide significant tax benefits to a buyer of 80% or more of a target corporation.  A 338(h)(10) election allows a buyer of stock of an S corporation or a corporation within a consolidated group to treat the transaction as an acquisition of 100% of the assets of … Continue Reading

Thinking of Expatriating? You May Be Leaving More Behind Than You Expected

U.S. citizens and long-term permanent residents who are considering relinquishing their U.S. citizenship or long-term permanent residency in the U.S. have more than just the exit tax imposed under Code § 877A to consider – they must also consider the impact the expatriation will have on their U.S. family members and other intended U.S. beneficiaries.  … Continue Reading
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