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Recent Articles & Treatises
- Registration now open for September 17, 2019 CPE Seminar, “IRC Sec. 199A: Wasn’t the Code to be Simplified?” August 26, 2019
- A Journey Through IRC Section 199A: Wasn’t the Code to be Simplified? July 25, 2019
- Tax News & Comment — August 2019 July 25, 2019
- Tax News & Comment – April 2017 March 13, 2017
- Tax News & Comment — May 2016 May 14, 2016
- FROM WASHINGTON & ALBANY — Current Election Probabilities; Tax Plans of Trump and Clinton May 13, 2016
- FROM FEDERAL AND NYS COURTS: Recent Developments & 2015 Decisions of Note May 13, 2016
- IRS & NYS DTF MATTERS: Recent Developments & 2015 Regs. & Rulings of Note May 13, 2016
- Creating and Maintaining Flexibility in Wills and Trusts May 13, 2016
- Escaping the Quandary Posed by Unreported Foreign Accounts May 13, 2016
- Like Kind Exchanges Alive and Well: An Update May 13, 2016
Most Popular
- Valuation Discounts for LLCs
- Executor and Trustee Commissions Under NY EPTL
- Taxation of Foreign Nongrantor Trusts: Throwback Rule
- Depreciation Recapture
- Legal Basis for Seeking Abatement of New York State Tax Penalties
- Letters Testamentary
- September 17 CPE Breakfast Lecture in Old Westbury, New York -- "IRC Sec. 199A: Wasn't the Code to be Simplified?"
- Tax and Legal Issues Arising In Connection With the Preparation of the Federal Gift Tax Return, Form 709 -- Treatise
- New York's Revised Decanting Statute Under EPTL §10-6.6
- Rev. Rul. 85-13: Is There a Limit to Disregarding Disregarded Entities?
Daily Archives: March 15, 2010
Refinancings Before and After § 1031 Exchanges
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
Posted in Federal Income Tax, Like Kind Exchanges
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Interest Abatement Denial Subject to Judicial Review
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
Posted in Tax Decisions, Tax News & Comment
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Life Insurance Trusts Mitigate Estate Tax Uncertainties
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
2006 REGS, IRS RULINGS & PRONOUNCEMENTS
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
The IRC § 2036 Trap in Planning With FLPs & Grantor Trusts
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
Posted in Family Entities
Tagged applicable exclusion amount, estate planning, estate tax, gift tax, gross estate, IRC § 2036, irs
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Law Offices of David L. Silverman 
Recent Tax Developments — October 2003
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 →