Tax and estate planning memorandum excerpts (2010‑2011) with no apparent misconduct

04/06/11 What it means to be a “statutory resident” of New York for income tax purposes — and 2011-03 how expensive that can be (Matter of Baker) 02/24/11 Updated “estate planning glossary” 2011-02 01/31/11 A discussion of “tax expenditures” and possible tax reform, based on reports from the 2011-01 President's Deficit Commission and the National Taxpayer Advocate 2010 12/23/10 Overview of the Tax Relief, Unemployment Insurance Reauthorization, and Job 2010-11 Creation Act of 2010 (Pub. L. 111-312): income tax and capital gains rates, tax-free distributions from IRAs to charity; estate and gift tax and GST provisions 11/30/10 Thoughts on the mid-term elections, and selected year-end planning points, along 2010-10 with some of the inflation-adjusted pension plan numbers for 2011; brief reminder of what low interest rates mean for certain planning techniques, including GRATs (grantor retained annuity trusts) and Sales to Defective Grantor Trusts 10/26/10 Estate of Tatum: another disclaimer gone awry — but taxpayer loses this time; 2010-09 possible timeline for retroactive reinstatement of estate tax and GST, based on Carlton, a 1994 Supreme Court estate tax case 09/14/10 Taxpayer successfully rescinds defective disclaimers and avoids significant gift tax 2010-08 liability (Breakiron); discussion of Bosch, the vintage case addressing when a state law holding is binding on the IRS 07/27/10 A discussion of next year’s likely return of “PEP” and “Pease” (indirect tax increases 2010-07 on higher earners) and the potential impact on charitable giving; two cases involving purported charitable gifts and a skeptical IRS: Hendrix and Free Fertility Foundation 07/01/10 A round-up of the still uncertain tax landscape: Sen. Bernie Sanders’ estate tax bill 2010-06 and its revenue raisers (consistent basis reporting, limits on valuation discounts and GRAT restrictions), “PAYGO” and Sen. Kyl’s estate tax proposal; Rep. Ryan’s “Roadmap”; NY drops “privity” requirement for executor’s suit against estate planning attorney (Schneider v. Finnman) 05/28/10 “Pierre II”. the Tax Court addresses the “step transaction doctrine” and valuation 2010-05 issues in a continuation of the Pierre v. Commissioner saga; valuation of fractional interests used in QPRTs (Ludwick v. Commissioner) 05/06/10 An updated discussion of some of the options to save for a child’s college education 2010-04 04/05/10 An overview of some of the provisions in the new health care legislation, particularly 2010-03 the new Medicare taxes; codification of “economic substance doctrine’; GRAT restrictions advance 02/28/10 President Obama's FY 2011 Budget — increases on higher earners, and estate and 2010-02 gift tax proposals: return to the 2009 estate tax regime, consistent values, modifying rules on valuation discounts and mandating minimum 10-year term and remainder interest for GRATs; under the “check-the-box” regulations, is a single member LLC disregarded for gift tax purposes? (Pierre v. Commissioner) Tax Topics — Table of Contents — 2013 — 3 HOUSE_OVERSIGHT_022332