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

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 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

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

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

IRS Says Aircraft Leasing Entity is Eligible for 1031 Tax Free Exchange Treatment Despite Leasing to Related Companies at No Profit

We previously wrote about how a recently passed Texas bill (S.B. 1396) will allow certain in-state aircraft purchases to qualify for a resale exemption from sales tax, with the tax instead applied to later leasing contract payments. Now, a new IRS Chief Counsel memo says that an aircraft leasing partnership that trades in an aircraft that … 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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