Archive for the ‘Post Mortem Planning’ Category

Tax Consequences in a Will Contest: The Story of a Modern Family

11-151-06 Matt Ahern (4x6@100)
Published: November 11th, 2014

By: Matthew J. Ahearn

Jay and Gloria are a wealthy, married couple.  Jay has an adult daughter from a previous marriage.  Her name is Claire.  Gloria also has a child from a previous marriage, a 12-year-old boy named Manny.  Jay and Gloria have a daughter together.  Her name is Chloe. Jay is old enough to be Gloria’s father.  The […]


11-151-06 Matt Ahern (4x6@100)
Published: August 29th, 2013

By: Matthew J. Ahearn

Today, the United States Treasury Department and the Internal Revenue Service issued a very significant and consequential ruling, Revenue Ruling 2013-17, addressing tax issues arising from the recent U.S. Supreme Court decision of U.S. v. Windsor, 133 S. Ct. 2675, issued on June 26, 2013. For federal tax purposes, the IRS will now recognize all same-sex […]

Portability Election Deadline Extended

Published: February 20th, 2012

On February 17, 2012, the IRS issued Notice 2012-21, which allows certain estates of married individuals who died during the first six months of 2011 to extend the time to make the portability election. Code section 2010(c) was amended in 2010 to allow the estate of a decedent who dies after 2010 and who is […]

AICPA’s Comments on Notice 2011-66

11-151-06 Matt Ahern (4x6@100)
Published: September 14th, 2011

By: Matthew J. Ahearn

On September 7, the AICPA Carryover Basis Task Force sent comments to the IRS on Notice 2011-66 making suggestions and requesting additional guidance on several issues, some of which are summarized below. They suggest a “policy of restraint” in auditing taxpayers having carryover basis issues for tax years after 3 years from the filing of the […]

Form 8939 Filing Deadline Extended

11-151-06 Matt Ahern (4x6@100)
Published: September 13th, 2011

By: Matthew J. Ahearn

Today, pursuant to Notice 2011-76 (the “Notice”), the IRS extended the due date for filing the Form 8939 from November 15, 2011 to January 17, 2012.  This Notice is unexpected considering shortly ago on August 29, 2011 the IRS issued Notice 2011-66 extending the deadline for filing the Form 8939 to November  15, 2011.  Rev. Proc. 2011-41 was […]

The Tax Relief Act of 2010: Three Estate Planning Themes

WebRes-Jack_Bovay (New)
Published: February 7th, 2011

By: Jack Bovay

My high school English teacher could never get me to find the themes of The Great Gatsby or The Red Badge of Courage (or anything else we read, for that matter), but apparently I am enough of a tax geek to see themes in the estate tax provisions of the Tax Relief Act of 2010. […]

Portability of Estate Tax Exemptions: General Rules

11-151-06 Matt Ahern (4x6@100)
Published: January 17th, 2011

By: Matthew J. Ahearn

We waited a long time, many would say too long, for estate tax legislation, and when it arrived in December, 2010, it provided some surprises. Perhaps the most significant surprise is the addition of portability of estate and gift tax exemptions between spouses, which had been included in prior bills but was not anticipated to […]