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…

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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…

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