New Estate and Gift Tax Clawback Proposed Regulations

On November 26, 2019, the Treasury Department and the IRS issued final regulations under Section 2010 which provided taxpayers with some much needed assurance that they would not be punished for utilizing their gift and estate tax exclusion (“Exclusion”) during their lifetime if Exclusion amounts were lower when they died (“Anti-Clawback Regulations”).[1] See Josh Sage’s…
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Recent CCA Addresses Valuations

The IRS Office of Chief Counsel recently issued CCA 202152018 (“CCA”), in which the IRS is attacking yet another business valuation.[1] The IRS takes the  position in the CCA that because the valuation used failed to account for a potential acquisition, the grantor retained annuity trust (“GRAT”) failed to properly qualify as a GRAT even…
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