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Trustees Internal Revenue Service Internal Revenue Code (IRC)

Rivkin Radler LLP

Trust Beneficiary Engages In Like Kind Exchange Using Trust Property

Rivkin Radler LLP on

It is a basic principle of the income tax that the gain or loss realized by a taxpayer from the conversion of property into cash, or from the exchange of property for other property that differs materially in kind from the...more

DarrowEverett LLP

Maximizing QSBS Benefits with Estate Planning: The Art of Stacking

DarrowEverett LLP on

The number of taxpayers seeking the benefits of Qualified Small Business Stock (“QSBS”) has picked up steam in recent years, particularly since the Tax Cuts and Jobs Act (“TCJA”) lowered the federal corporate tax rates to...more

DarrowEverett LLP

1031 Exchanges and the Complexities of Seller Financing

DarrowEverett LLP on

With interest rates nearly the highest they’ve been in decades, but property prices still high, sellers and buyers are looking for ways to finance real estate transactions while also availing themselves of IRC § 1031’s...more

ArentFox Schiff

Self-Directed IRAs and the Prohibited Transaction Rules – Part 1

ArentFox Schiff on

Part 1: Permitted Investments and Compliance - The self-directed individual retirement account (IRA) is an increasingly popular option for an IRA account owner, especially those owners who have significant net worth and...more

Proskauer Rose LLP

Wealth Management Update - April 2023

Proskauer Rose LLP on

The April Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.0%. The April applicable federal rate (“AFR”) for use with a sale to a defective grantor trust or intra-family loan...more

Maynard Nexsen

The Reach of an IRS Levy on Beneficiaries of Corporate Trustees

Maynard Nexsen on

The IRS’s reach in collecting unpaid and assessed taxes is broad, pervasive, and aimed “to reach every interest in property that a taxpayer may have” United States v. National Bank of Commerce, 472 U.S. 713, 719–720 (1985)...more

Miles & Stockbridge P.C.

Bankruptcy Court Within Fourth Circuit Permits Fraudulent Conveyance Claims to Move Forward Under IRS 10-Year Reach Back Period

Miles & Stockbridge P.C. on

A recent opinion by the United States Bankruptcy Court for the Western District of North Carolina kept alive a bankruptcy trustee’s fraudulent conveyance claims based on, in part, the Internal Revenue Code (“IRC”) 10-year...more

Levenfeld Pearlstein, LLC

Frank Aragona Trust: A Taxpayer Win

In a case of first impression, Frank Aragona Trust v. Commissioner, 142 T.C. No. 9 (Mar. 27, 2014), the Tax Court held that a trust could materially participate in a trade or business based upon the activities of the...more

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