AICPA’s Comments on Notice 2011-66

By rwithers | September 14, 2011

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…

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Form 8939 Guidance Concerning the Generation-Skipping Transfer (GST) Tax

By rwithers | August 10, 2011

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…

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Form 8939 Notice and Guidance

By rwithers | August 8, 2011

By 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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