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 [...]
New Offshore Voluntary Disclosure Program for 2012
Yesterday, the IRS started the Offshore Voluntary Disclosure Program (2012 OVDP), which is a modified continuation of the 2011 Offshore Voluntary Disclosure Initiative (2011 OVDI). The IRS will also release a new FAQ and provide additional details of 2012 OVDP on its website in the coming months. 2012 OVDP comes on the heels of last [...]
Form 8939 and Instructions
This is quick alert for our readers. Yesterday, the IRS posted Form 8939, Allocation of Basis Increase for Property Acquired from a Decedent, and today, the IRS posted the instructions to the Form 8939. The Form 8939 has been substantially revised since the last release, and this is the first set of instructions issued by [...]
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 [...]
Form 8939 Notice and Guidance Concerning Transfer Certificates and the Section 645 Election
By Matthew J. Ahearn and Brian M. Malec This is our final post concerning Notice 2011-66, in which we will address transfer certificates and the Code section 645 election. Please check back here as we will delve into Rev. Proc. 2011-41 and the optional safe harbor guidance under Section 1022 in future posts. Transfer Certificates [...]
Form 8939 Guidance Concerning the Generation-Skipping Transfer (GST) Tax
By Matthew J. Ahearn and Brian M. Malec This post continues on from our immediately previous posting concerning the Section 1022 election and filing requirements. In this post, we will discuss the GST tax guidance in Notice 2011-66 (the “Notice”). A. Decedents Who Died in 2010. TRUIRJCA retroactively reinstated the GST tax for 2010, but [...]
Form 8939 Guidance Concerning Section 1022 Election and Filing Requirements
By Matthew J. Ahearn and Brian M. Malec On August 5, 2011, the IRS released long-awaited guidance for estates of decedents dying in 2010 in the form of IRS Notice 2011-66 (the “Notice”). The Notice addresses certain issues relating to the election out of the federal estate tax for decedents dying in 2010. The Notice [...]
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