Taxpayers sometimes die with a right to gross income that has not been received at the time of death and is not re-portable on the decedent's final or other pre-death income tax return, that is, with an entitlement to items of "income in respect of a decedent" (IRD). An estate with charitable...

Representative Earl Pomeroy (D. North Dakota) has introduced a bill, HR 436, that would have significant impact on the value of interests in real estate, investment holding and possibly operating entities, for estate and gift tax purposes. This echoes proposals made during the Clinton...

The alternate valuation rules in Section 2032 can alleviate the hardship that a decedent's estate may experience as a result of a decrease in the value of the gross estate from the date of the decedent's death to the date on which estate tax has to be paid. These rules permit an executor to...

In this article, the authors revisit their prior article on Circular 230 (see Tax Notes, Apr. 4, 2005, p. 61), focusing in particular on the amendments Treasury adopted on May 18. They consider the meaning of an important, new safe harbor under which transactions that are consistent with the...

In this report, Blattmachr and Gans explain how new regulations promulgated in January make reaching and fundamental changes to some tax rules that are dependent on the concept of fiduciary accounting income (FAI) under local law. The new regulations, they write, generally will respect a...

Tax-efficient wealth transfer is an important goal of most sound estate planning strategies. A grantor retained annuity trust (GRAT) is a wealth transfer technique created by Section 2702 of the Internal Revenue Code and corresponding Treasury Regulations. Taxpayers and practitioners therefore...