Daily Archives: March 15, 2010

Refinancings Before and After § 1031 Exchanges

Posted on March 15, 2010 by David L. Silverman, J.D., LL.M. (Taxation)

Cash (“boot”) received in a like-kind exchange results in taxable gain to the extent of realized gain. If the taxpayer exchanges Greenacre, whose adjusted basis is $1 million, for $1 million in cash and Whiteacre, worth $1 million, the taxpayer … Continue reading →

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Recent Tax Developments — October 2003

Posted on March 15, 2010 by David L. Silverman, J.D., LL.M. (Taxation)

The IRS announced on 9/15 that it had reached agreements with 40 states to trade information on unlawful tax shelters. Arthur Roth, Commissioner of the NYS-DTF, said the potential revenue loss was in the “tens of millions.” The IRS is … Continue reading →

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Interest Abatement Denial Subject to Judicial Review

Posted on March 15, 2010 by David L. Silverman, J.D., LL.M. (Taxation)

The 5th Circuit Court of Appeals has held that in amending IRC § 6404(e), which grants IRS the authority to abate an assessment of interest attributable in whole or in part to any error or delay by the IRS in … Continue reading →

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1999 Regs, IRS Rulings & Pronouncements

Posted on March 15, 2010 by David L. Silverman, J.D., LL.M. (Taxation)
Posted in IRS Matters, Tax News & Comment | Leave a comment

Life Insurance Trusts Mitigate Estate Tax Uncertainties

Posted on March 15, 2010 by David L. Silverman, J.D., LL.M. (Taxation)

To view printer-friendly Memorandum, press here: Life Insurance Trusts Mitigate Estate Tax Uncertainties.wpd Irrevocable life insurance trusts (ILITs) enjoy vastly preferential status under the income and transfer tax laws. Properly structured, proceeds are not included in the insured’s gross estate. … Continue reading →

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2006 REGS, IRS RULINGS & PRONOUNCEMENTS

Posted on March 15, 2010 by David L. Silverman, J.D., LL.M. (Taxation)

Printer-friendly PDF version: 2006 Regs., Rulings, & IRS Pronouncements.wpd Since IRA accounts often reflect a lifetime of retirement savings, their inclusion in a QTIP trust is important. Rev. Rul. 2000-2 stated that IRA proceeds may qualify for a QTIP election … Continue reading →

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The IRC § 2036 Trap in Planning With FLPs & Grantor Trusts

Posted on March 15, 2010 by David L. Silverman, J.D., LL.M. (Taxation)

Printer-friendly PDF Memorandum:  The IRC § 2036 Trap in Planning With FLPs & Grantor Trusts.wpd The IRS has advanced many theories to challenge the gift and estate tax savings occasioned by the use of family entities and grantor trusts in … Continue reading →

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