Portability Election Deadline Extended
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
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
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
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
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 [...]
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