Government Relations & Lobbying
Bringing Client Goals to Fruition with Substantial Relationships and Deep Knowledge Our Government Relations & Lobbying team blends strong knowledge with impactful relationships. In fact,…
Bringing Client Goals to Fruition with Substantial Relationships and Deep Knowledge Our Government Relations & Lobbying team blends strong knowledge with impactful relationships. In fact,…
Dean Mead’s Tax Department handles tax planning issues for businesses and individuals. The attorneys in our department have extensive experience in a full range of…
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…
Read MoreBy 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…
Read MoreBy 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…
Read MoreBy 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…
Read MoreBy Matthew J. Ahearn and Brian M. Malec On Friday, August 5, 2011, the IRS issued Notice 2011-66 and Rev. Proc. 2011-41 to provide guidance concerning the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (TRUIRJCA). Under TRUIRJCA, an election may be made to opt out of the estate tax and into…
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