Wandry v Commissioner: Tax Court Blesses Use of Defined Value Formula Clause
In an extremely important taxpayer victory, the United States Tax Court issued a memorandum opinion upholding the use of a defined value formula clause to fix the value of the donor’s gift for federal gift tax purposes. Wandry v. Commissioner, T.C. Memo 2012-88 (March 26, 2012). This type of formula clause is intended to prevent [...]
2011 Florida Legislative Update Seminar – Materials
For those of you who were unable to attend our recent seminar covering Florida’s new estate planning legislation, we have posted our materials on our website. We hope you find them useful.
Final Regulations Regarding Extensions of Time for Pass-Through Entities to File Returns
Today, the Treasury Department and IRS issued final regulations concerning automatic extensions of time to file returns for pass-through entities (i.e., partnerships, s-corporations, trusts and estates). The regulations are effective today (June 24, 2011). Prior to 2008, pass-through entities could obtain an automatic six (6) month extension of time to file their income tax returns. [...]
Florida Legislation Regarding Inherited IRAs and LLCs – Update
Yesterday, Governor Rick Scott signed into law House Bill 253, regarding limited liability companies, and House Bill 469, regarding Inherited IRAs. We reviewed those Bills in a post on May 4.
2011 Florida Legislative Update Seminar
We are extending an invitation to our readers to attend our seminar on Tuesday, June 21, 2011 from 11:30 a.m. to 1:30 p.m. at the Orange County Bar Association, 880 N. Orange Avenue, Orlando covering recent Florida legislation affecting estate planning. The topics will include limited liability companies, inherited IRAs, the Florida Uniform Prudent Management of Institutional Funds Act, [...]
Florida Legislation Regarding Inherited IRAs and LLCs
The following article was recently submitted to Leimberg Information Services by Lauren Detzel and Brian Malec, contributors to this blog. Leimberg Article Executive Summary: In LISI Asset Protection Planning Newsletter #173, we reported on Florida’s legislative efforts to statutorily protect inherited IRAs from the claims of creditors of a debtor beneficiary under Florida state law. [...]
Are Family Trust Companies (FTC) in Florida’s Future? An Update on the Effort to Bring FTCs to Florida.
In Fall 2008, I had the opportunity to join an ad hoc subcommittee comprised of members of the Tax and Real Property, Probate and Trust Law Sections of the Florida Bar to prepare and submit comments to the IRS in response to a proposed Revenue Procedure contained in IRS Notice 2008-63, which addressed the income, [...]
Linton v. U.S.: Indirect Gift of Property Owned by LLC
In a victory for the taxpayer, the Ninth Circuit Court of Appeals reversed the lower court’s grant of summary judgment in favor of the IRS. The Lintons met with their attorney on January 22, 2003 to form, and transfer property to, a limited liability company (LLC). The Lintons also executed trust agreements for their children [...]
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