News & Analysis as of

Interest Rates Tax Court

Bressler, Amery & Ross, P.C.

How to Take Advantage of Changes in Interest Rates For Gift and Estate Tax Savings

A recent Tax Court order highlights the gift and estate planning opportunities afforded when a senior family member makes loans to other family members. In Galli v. Commissioner, Docket Nos. 7003-20 and 7005-20, the Court had...more

Rivkin Radler LLP

“Hey Mom, Can I Have A Few Bucks?” Is It A Loan? A Gift? A Little of Each?

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A parent will sometimes transfer money to a child to enable the child to make an investment that the child could not otherwise make on their own. For example, the child may have identified an attractive business opportunity...more

Davies Ward Phillips & Vineberg LLP

Federal Court of Appeal Confirms CRA Can Collect Arrears Interest Despite Absence of a Tax Debt

The Federal Court of Appeal (FCA) recently dismissed the Bank of Nova Scotia’s (BNS) appeal and upheld the Canada Revenue Agency’s (CRA) practice of charging arrears interest on a non-existent tax debt where audit adjustments...more

Rivkin Radler LLP

Tax Planning for Business Owners Who Shortchange Themselves

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Something’s Wrong- Of late, a not insignificant number of the business owners with whom I’ve been working have raised some concern over whether they are financially prepared for the next stage of their lives. ...more

Rivkin Radler LLP

Shared Appreciation Interest: Debtor-Creditor or Partners?

Rivkin Radler LLP on

When is a loan not a loan? When it’s something else – for example, equity. This is one of those pesky facts and circumstances issues that plague courts, taxpayers, and tax advisers to no end. Debt- On one end of the...more

Proskauer Rose LLP

Wealth Management Update - February 2022

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February 2022 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split-Interest Charitable Trusts....more

Farrell Fritz, P.C.

Intra-Family Loan: A Gift Alternative In Turbulent Times?

Farrell Fritz, P.C. on

Woe to Us? We live in strange times. The coronavirus pandemic hit the United States hard, the scientific community fears a second round later this year, and there have been wildly differing estimates over when an...more

Proskauer Rose LLP

Wealth Management Update - July 2020

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July 2020 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intrafamily Loans and Split-Interest Charitable Trusts - The July Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more

McDermott Will & Emery

Weekly IRS Roundup March 9 – 13, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 9 – 13, 2020. March 10, 2020: The IRS published a practice unit on how to compute the...more

Proskauer Rose LLP

Wealth Management Update - March 2020

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March 2020 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - Important federal interest rates continue to hold relatively steady. The March Section 7520...more

Proskauer Rose LLP

Wealth Management Update - December 2019

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December 2019 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split-Interest Charitable Trusts - The December Section 7520 rate for use with estate planning techniques such as CRTs,...more

Eversheds Sutherland (US) LLP

Maryland’s limited interest on Wynne refunds ruled unconstitutional

On May 23, 2018, the Maryland Tax Court held that Maryland’s limitation of interest on refunds resulting from the US Supreme Court’s decision in Comptroller of the Treasury of Maryland v. Wynne, 135 S. Ct. 1787 (2015)...more

Morrison & Foerster LLP

Indiana Tax Court Allows Deductions for Interest Paid on Intercompany Loans and Holds That Gain from Sale of Partnership Was...

On July 11, 2017, the Indiana Tax Court released a decision in E.I. DuPont de Nemours and Company v. Indiana Department of State Revenue. The Tax Court held that the Indiana Department of Revenue had improperly reclassified...more

Proskauer Rose LLP

Wealth Management Update - December 2016

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December Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The December § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more

Proskauer Rose LLP

Wealth Management Update - July 2016

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July Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The July § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and...more

Proskauer Rose LLP

Wealth Management Update - March 2016

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March Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The March § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and...more

Proskauer Rose LLP

Wealth Management Update - February 2016

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February Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The February § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more

Proskauer Rose LLP

Wealth Management Update - November 2015

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November Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The November § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more

Proskauer Rose LLP

Wealth Management Update - October 2015

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October Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The October § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more

Proskauer Rose LLP

Wealth Management Update - August 2015

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August Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The August § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and...more

Proskauer Rose LLP

Wealth Management Update - June 2015

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June Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The June § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and...more

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