The Internal Revenue Service (“IRS”) issued Private Letter Ruling (“PLR”) 201647001 in November of 2016, in which it took the position that a modification to an irrevocable grantor trust to add a discretionary income tax reimbursement clause did not change the beneficial interests in the trust, and therefore did not result in a gift, because…
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In the Heiting v. United States[1] decision issued on October 18, 2021, the United States Court of Appeals for the Seventh Circuit affirmed a district court decision[2] to dismiss a couple’s claim for a refund of taxes, rejecting the taxpayers’ argument that the repurchase of restricted stock previously sold by their trustee was effectively a…
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This article will be the final in a series of articles covering the installment method of reporting income. In our first article of the series, we discussed §453 and the basics of the installment method of income tax reporting.[1] As noted in the article, the installment method of reporting income can be a powerful tax…
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Introduction Last year I discussed President Joe Biden’s Proposed Tax Policy For Individuals, Charles J. Allen discussed the tax plans of the democratic presidential candidates, and Josh Sage discussed some of Biden’s potential changes. We are now a few months into President Biden’s tenure and the first ripples of tax reform can be felt by…
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Here we are coming upon the fourth anniversary of the one of the most shocking nights of our country since perhaps the Battle of Saratoga and one of the largest cash outlays by our government ever known by means of the CARES Act. On the heels of these events Democrats are setting the stage to…
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I was fortunate enough to attend the 54th annual Heckerling Institute on Estate Planning in Orlando. Heckerling is known worldwide for being one of the most innovative and informative estate planning conferences put on. The topics are always relevant and timely, and there are always some new and innovative planning techniques and ideas presented. Additionally,…
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