Daily Archives: February 18, 2015

IRS & NYS DTF Matters; Recent Developments & 2014 Regs. & Rulings of Note

I. New York State Matters NYS Amends Estate & Gift Tax Beginning April 1, 2014, the NYS estate exemption will increase every 12 months through 2017. On April 1, 2014, the NYS exemption became $2.0625; on April 1, 2015, $3.125 … Continue reading

Posted in Estate Planning, Federal Gift Tax, Federal Income Tax, Grantor Trusts, Income Taxation of Nongrantor trusts, Portability | Tagged , , , , , , , , , , , , , , ,

The Evolution of Trusts in American Jurisprudence

I. Introduction A trust is a relationship whereby a trustee holds property for the benefit the beneficiary, or cestui que trust. A division of ownership occurs between the trustee, who holds legal title, and the beneficiary, who holds equitable title. … Continue reading

Posted in The Evolution of Trusts in American Jurisprudence, Treatises, Trusts | Tagged , , , , , , , , , , , , , , , , , , , , ,

Private Letter Ruling Requests

I. Introduction Private letter rulings are in the nature of “advisory” rulings by the IRS concerning the tax implication of income or estate transactions contemplated by taxpayers. As stated in Rev. Proc. 2015-1, the IRS generally issues a letter ruling … Continue reading

Posted in Federal Income Tax, Federal Tax Litigation, IRS, IRS Rulings & Regulations | Tagged , , , , , , , , , ,

Federal Tax Litigation

I. Introduction In general, the statute of limitations for the IRS to assess is three years after the date the return is filed or two years from the date the tax is paid. After audit, the IRS may issue a … Continue reading

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