A common question that arises when preparing federal gift tax returns is whether a gift in trust qualifies not only for the gift tax annual exclusion but also for the lesser know (and lesser understood) generation-skipping transfer (“GST”) tax annual exclusion. This article will clarify when gifts in trust…
Category: Tax Planning
The IRS issued Rev. Proc. 2022-19, which provides simplified procedures for S corporations and their shareholders to resolve six frequently-encountered issues. For these issues, Rev. Proc. 2022-19 allows S corporations and their shareholders to obtain relief without requesting a private letter ruling (PLR). The IRS identified these issues as not…
On August 24, 2022, the Internal Revenue Service (“IRS”) released Notice 2022-36, which provides relief for eligible taxpayers from failure to file penalties for specified tax returns for the 2019 and 2020 tax years that are filed on or before September 30, 2022. The Department of the Treasury and the…
››The Internal Revenue Service recently issued Rev. Proc. 2022-32, which permits certain estates up to 5 years to file a federal estate tax return (Form 706) in order to make a portability election and thereby transfer a decedent’s unused estate tax exemption to his or her surviving spouse; an estate…
When a business owner receives a letter of intent from a buyer to purchase their business, the business owner may be surprised to learn that the transaction is contingent on the underlying business entity engaging in an “F” reorganization. The business owner may be curious as to why a potential…
