Document Text Content
Blanche Lark Christerson
Managing Director, Senior Wealth Planning Strategist
Tax Topics
Table of Contents
2013
2013
12/20/13 Budgets, tax reform and “extenders”; end of the year round-up 2013-12
11/15/13 The government shutdown, and selected inflation-adjusted numbers for 2014 and
end-of-the-year planning points
2013-11
10/07/13 A review of basic planning points 2013-10
08/30/13 Revised discussion of Windsor, reflecting guidance from the IRS and the Treasury
Department, issued on August 29, 2013
08/28/13 United States v. Windsor: the Supreme Court rejects Section 3 of DOMA, which
defines “marriage” as only between a man and a woman
07/01/13 Selected planning points: the now “permanent” $5 million exclusion, indexed for
inflation, state estate taxes and “portable” spousal exclusions
2013-09
2013-08
2013-07
05/29/13 Updated discussion of selected options to save for a child’s college education 2013-06
04/29/13 Selected tax provisions from President Obama’s Fiscal Year 2014 Budget 2013-05
03/21/13 Updated estate planning glossary and selected income tax terms 2013-04
02/20/13 Conservation easement flunks as charitable contribution (Belk); “DD” and the cost of
employer-provided health care; two important 100-year anniversaries; some lesserknown
provisions of the American Taxpayer Relief Act
01/25/13 Selected numbers from official IRS 2013 inflation-adjustments (Rev. Proc. 2013-15);
façade easement has zero value as charitable deduction (Scheidelman)
2013-03
2013-02
01/10/13 Selected overview of the “American Taxpayer Relief Act of 2012” (H.R. 8): 2001 and
2003 tax cuts largely made permanent, but higher taxes for the top 1% to 2%
2013-01
2012
12/31/12 Proposed regulations on the 3.8% tax on “net investment income”; Wandry again, and
how many gift tax dollars the “defined value” clause saved
11/30/12 The “fiscal cliff,” alternative minimum tax and transfer taxes; IRS “non-acquiesces” in
Wandry; possible taxpayer relief for those affected by Hurricane Sandy
10/31/12 Countdown to the election; selected 2013 inflation-adjusted numbers and various
planning points; Wandry appeal withdrawn
09/25/12 The looming “fiscal cliff” and the shape of possible future tax legislation; how NOT to
substantiate a charitable deduction (Mohamed v. Commissioner); Wandry appealed
2012-09
2012-08
2012-07
2012-06
07/31/12 The Supreme Court’s health care decision: The Affordable Care Act upheld 2012-05
06/11/12 Wandry v. Commissioner: yes, another taxpayer victory using a “defined value”
formula clause – but caution may be in order
04/19/12 Supreme Court arguments on the health care law; Medicare taxes taking effect in
2013: 0.90% on the wages of “high earners” and 3.8% tax on “net investment
income”; the Buffett Rule and the “Paying a Fair Share Act” (S. 2230)
03/08/12 Tax proposals on “high-income” taxpayers from President Obama’s Fiscal Year 2013
Budget and the Treasury Department’s “Green Book”
01/23/12 Estate of Petter v. Commissioner: another taxpayer victory using a “defined value”
formula clause, and the legacy of Procter v. Commissioner
2012-04
2012-03
2012-02
2012-01
2011
12/02/11 “Super Committee” bows out; 2012 inflation-adjusted numbers and various planning
points; the “Sensible Estate Tax Act of 2011” (H.R. 3467)
10/21/11 The American Jobs Act of 2011: the 28% limitation, the millionaires’ surtax, and the
“Buffett Rule”
09/16/11 The Budget Control Act of 2011 (Pub. L. 112-25) and the “Super Committee”: reduce
the deficit – or else!
07/28/11 How certain discretionary language almost made a credit shelter trust taxable in the
trustee/beneficiary’s estate (Estate of Chancellor v. Commissioner)
06/13/11 A Tax Court valuation case that illustrates just how far apart the experts can be, and
how a judge evaluates those experts (Estate of Mitchell)
05/03/11 Additional thoughts on last December’s 2010 Tax Act: lifetime gifts (GRATs, Sales to
Defective Grantor Trusts and QPRTs) and how “credit shelter trusts” are still relevant
despite the “portability” of a deceased spouse’s estate tax exclusion
2011-09
2011-08
2011-07
2011-06
2011-05
2011-04
Tax Topics – Table of Contents – 2013 – 2
04/06/11 What it means to be a “statutory resident” of New York for income tax purposes – and
how expensive that can be (Matter of Baker)
2011-03
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
President’s Deficit Commission and the National Taxpayer Advocate
2011-01
2010
12/23/10 Overview of the Tax Relief, Unemployment Insurance Reauthorization, and Job
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
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;
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
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
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
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
issues in a continuation of the Pierre v. Commissioner saga; valuation of fractional
interests used in QPRTs (Ludwick v. Commissioner)
2010-11
2010-10
2010-09
2010-08
2010-07
2010-06
2010-05
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
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
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)
2010-03
2010-02
Tax Topics – Table of Contents – 2013 – 3
01/26/10 The 2010 planning landscape: NO estate tax, GST or basis adjustment rules; what
Congress may do; possible constitutional “due process” challenge; what can go
wrong when documents are wrong about how property is titled (Beudert-Richard v.
Richard)
2010-01
2009
12/22/09 The imminent demise of the estate tax? Possible effect on formula provisions and the
difficulties of modified carryover basis; extenders bill and carried interest; proposed
stock transactions tax; importance of keeping beneficiary designations current
(Kennedy v. DuPont SIP)
09/30/09 More on Roth IRA conversions: calculating what the taxable amount may be; how a
“decoupled” state may tax a non-resident’s property, even if it’s passing to a surviving
spouse; NY advisory opinion on non-resident’s proposed condo purchase (TSB-A-
08(1)M)
08/31/09 What may happen with estate tax repeal and tax-free IRA distributions to charity;
early 2009 AMT “patch”; Roth IRA conversions in 2010 – restrictions will be gone so
that anyone may convert a “regular” IRA to a Roth
07/28/09 Some pros and cons of several options to pay for health care reform; the case of the
“tainted witness” and a will’s tax apportionment clause (Estate of Wu); how some
states are dealing with economic adversity
06/15/09 OMB’s “Analytical Perspectives” and Treasury Department’s “Green Book” offer
insights on Obama tax proposals and outline of estate and gift tax proposals:
consistent values, modifying rules on valuation discounts and minimum 10-year terms
for GRATs; taxing employer-provided health care?; new mortality tables and QPRTs;
New York’s increased taxes and estimated tax payments
04/20/09 The “Taxpayer Certainty and Relief Act of 2009” (S. 722) – makes lower income tax
rates permanent, increases higher rates, and freezes the estate tax at 2009 levels;
focus on whether Congress might reinstate the state death tax credit; new task force
on tax reform
03/19/09 President Obama’s FY 2010 budget proposal: higher rates, limits on itemized
deductions and the personal exemption phase-out; the interaction of the regular tax
with the AMT; historical income tax and capital gains tax rates; S. 394 would enhance
the tax treatment of art and collectibles
02/09/09 Rep. Pomeroy’s estate tax bill (H.R. 436); basic planning points; basis adjustment
rules, including modified carryover basis in 2010; “The Rangel Rule” (H.R. 735); intrafamily
loans
01/12/09 Suspension of 2009 required minimum distributions under The Worker Retiree and
Employer Recovery Act of 2008 (Pub. L. 110-458); a brief mention of another “bad
facts” limited partnership case (Hurford)
2009-10
2009-08
2009-07
2009-06
2009-05
2009-04
2009-03
2009-02
2009-01
Tax Topics – Table of Contents – 2013 – 4
2008
12/02/08 Prospective tax increases and their possible revenue implications; inflation-adjusted
numbers for 2009 and selected planning points
11/04/08 The Emergency Economic Stabilization Act of 2008 (Pub. L. 110-343): AMT
extenders and ISO relief, tax-free IRA distributions to charity, deduction for state and
local sales taxes, broker basis reporting, and harmonizing preparer penalties for
undisclosed positions; making lemonade out of lemons – coping with the market
decline
09/30/08 A discussion of the upcoming $3.5 million estate tax exclusion, and how it affects
planning in “decoupled” states, especially for married couples
08/29/08 A selected review of major tax legislation during the Bush administration, and a
snapshot of the tax proposals of Senators McCain and Obama
07/31/08 No discount for “restricted management accounts” (Rev. Rul. 2008-35); final regs on
“grantor retained interest trusts” (T.D. 9414)
06/30/08 Charitable remainder trusts and UBTI: final regs (T.D. 9403); charitable lead trusts
and “tiering” provisions: proposed regs (REG-101258-08)
05/30/08 Supreme Court holds that muni bonds still tax free (Kentucky v. Davis); IRS issues
proposed regs on alternate valuation (REG-112196-07; Kohler v. Commissioner)
04/28/08 The awful AMT and its disappearing exemption; Notice 2008-22 and a trust grantor’s
“nonfiduciary” power to swap trust property for property of equivalent value; planning
techniques that work well in a low-interest rate environment
2008-11
2008-10
2008-09
2008-08
2008-07
2008-06
2008-05
2008-04
03/31/08 Disclaimers and self-adjusting valuation clauses (Christiansen) 2008-03
02/26/08 More on the new preparer penalties: Notice 2008-13 2008-02
01/28/08 Supreme Court affirms that trust investment advisory fees subject to 2% floor
(Knight); wash sale rules and IRAs; survivorship and the marital deduction (Lee)
2008-01
2007
12/21/07 AMT patch, cont’d.; 11 th Circuit reverses Tax Court: built-in capital gains tax
liability reduces value of closely held corporation: Estate of Jelke (General Utitilies
doctrine; willing buyer-willing seller; IRA implications)
11/20/07 AMT patch; inflation-adjusted numbers for 2008 and planning points; 0% rate for
dividends and capital gains
10/26/07 Preparer penalties: the new rules under the Small Business and Work Opportunity
Act of 2007; transition rules under Notice 2007-54
2007-12
2007-11
2007-10
09/28/07 Charlie Rangel’s proposal; AMT and estimated tax; taxing “carried interest” 2007-09
08/31/07 Saving for college: the “kiddie tax” and the pros and cons of different savings vehicles 2007-08
Tax Topics – Table of Contents – 2013 – 5
07/31/07 Davis v. Kentucky Revenue Department – Supreme Court to examine muni bond
taxability; proposed regs on trust investment fees and the 2% floor (REG-128224-06)
06/28/07 Proposed regs on grantor retained income trusts (REG-119097-05); why timing of
payments matters; why there’s a 7520 rate; Rudkin update
05/31/07 “Kiddie tax” changes; custodial accounts; “pay-go”; whither the estate tax; get a good
valuation expert! (Kimberlin)
2007-07
2007-06
2007-05
04/27/07 2 nd Circuit affirms that trust investment fees subject to 2% floor: Rudkin 2007-04
03/29/07 IRS Clarification: non-spousal rollovers and tax-free IRA distributions to charity
(Notice 2007-7); tax patents; Chuck Grassley on the AMT and the “tax gap”
2007-03
02/28/07 Estate Planning Glossary 2007-02
01/30/07 The “First 100 Hours”; President Bush’s health care proposals; 2006 Annual Report of
the National Taxpayer Advocate
2007-01
2006
12/29/06 The Tax Relief and Health Care Act of 2006 (Pub. L. 109-432): “extenders”; health
savings accounts; AMT refundable credit; charitable remainder trusts and UBTI;
permanent capital gain treatment for self-created musical works
2006-11
11/22/06 The mid-term elections; 2007 inflation-adjusted numbers 2006-10
10/23/06 More on the Pension Protection Act of 2006: fractional interest gifts and $100,000 taxfree
IRA contributions to public charities; Charlie Rangel and AMT reform;
Connecticut marital deduction for same-sex couples
09/08/06 The Pension Protection Act of 2006 (Pub. L. 109-280): selected retirement and
charitable provisions
07/31/06 Estate Tax and Extension of Tax Relief Act of 2006 (H.R. 5970); Illinois decoupling
(McGinley v. Madigan); non-resident income taxation and out-of-state property
2006-09
2006-08
2006-07
06/27/06 Permanent Estate Tax Relief Act of 2006 (PETRA, H.R. 5638) 2006-06
05/31/06 Tax Increase Prevention and Reconciliation Act of 2005 (Pub. L. 109-222): “kiddie
tax”; conversions to Roth IRAs; expatriate income and housing exclusion; capital
gains treatment for self-created musical works
04/28/06 The AMT and stock options: capital loss carryback prohibitions apply to AMT as well
(Merlo); attempted assignment of income fails (McManus); assignment of income:
non-qualified stock options and charitable remainder trusts
2006-05
2006-04
03/29/06 4 th Circuit upholds IRS win in Chawla, but “insurable interest” issue still dangles 2006-03
02/22/06 Charitable Remainder Trust Safe-Harbor (Notice 2006-15); more on prepaid tuition;
debts, forgiveness and taxes
2006-02
Tax Topics – Table of Contents – 2013 – 6
01/27/06 Prepaid tuition (PLR 200602002); gift and estate tax reminder; “Personal Revival
Trusts” for cryonauts
2006-01
2005
12/27/05 Tax Reform Panel Recommendations; Ron Wyden’s “Fair, Flat Tax Act of 2005” 2005-12
11/18/05 Hurricane Katrina Provisions; 2006 inflation-adjusted numbers; sale of remaining
lottery payments is not a sale of a “capital asset” (Prebola)
2005-11
10/18/05 Saving for College – round-up of options 2005-10
09/30/05 Ittleson – New York taxes sale of non-resident’s artwork 2005-09
09/08/05 Estate tax thoughts; GST consequences of taxable trust renunciation (PLR
200532024); note about the “rule against perpetuities”
2005-08
07/29/05 Strangi – 5 th Circuit upholds IRS win in Texas FLP case 2005-07
06/30/05 Circular 230 2005-06
05/27/05 Estate planning glossary; Washington state’s new estate tax 2005-05
04/20/05 New Jersey loses on decoupling case (Oberhand); retroactive tax changes
(Nationsbank); charitable remainder trust “safe harbor” rules and the right of election
(Rev. Proc. 2005-24)
03/28/05 Insurable interests and trusts: Chawla; “frivolous arguments to avoid when paying
taxes” (Notice 2005-30)
2005-04
2005-03
02/18/05 Washington State decoupling struck down: Hemphill 2005-02
01/28/05 Social security, the estate tax and tax reform; several cases: Banks (contingent
attorney’s fees); Harkins (“corporation sole”); Davis (marital deduction)
2005-01
2004
12/28/04 The Barnes Foundation 2004-15
11/24/04 2005 inflation-adjusted numbers; how a low 7520 rate affects planning techniques 2004-14
11/05/04 Tax reform: flat tax and consumption tax; American Jobs Creation Act deductions for
sales tax and attorneys’ fees; New York tax law change: non-resident’s sale of co-op
now taxable
10/08/04 The Working Families Tax Relief Act of 2004 (H.R. 1308): extension through 2010 of
10% and 15% brackets; that “ridiculously complex” tax code; a word on PORC;
reminder about low 7520 rates
09/10/04 Turner v. Commissioner (formerly Thompson): 3d Circuit affirms IRS Tax Court win
against FLP (family limited partnership); Turner contrasted with Kimbell
2004-13
2004-12
2004-11
Tax Topics – Table of Contents – 2013 – 7
08/03/04 Tax Court says stock transfers to FLP are indirect gifts (Senda); co-op’s real estate
taxes not deductible against AMT (Ostrow and Guterman)
07/14/04 IRS addresses grantor trust rules and implications of tax reimbursement clauses
(Rev. Rul. 2004-64); LUST tax
06/25/04 H.R. 4520, the export bill; proposals for state and local sales tax deduction and
deferred compensation; House bills; temporary Connecticut decoupling; 7520 rate
chart
05/28/04 Kimbell v. U.S. – 5 th Circuit hands taxpayer a victory in FLP case; how the applicable
federal rates are determined
04/28/04 Export bill: economic substance doctrine, expanded “kiddie tax”; no dice on offsetting
gambling losses (TAM 200417004); QSLOB election
04/02/04 President Bush’s 2005 budget takes aim at 529 plan “loopholes”; deductibility of
attorneys’ fees – Supreme Court grants cert on Banaitis and Banks
03/18/04 Impact of 2001 and 2003 tax law changes and interplay with AMT; reminder about low
7520 rates
02/27/04 More thoughts on “decoupling”: New York, New Jersey and Connecticut – the power
of lifetime gifts; pro-rating the tax on a New York trust that changes situs
02/03/04 Tax clause nightmare: Lurie v. Commissioner, or the pain of charging taxes to a nontaxable
share; interrelated computations
01/14/04 New York fiduciary income tax and trust situs: Estate of William Rockefeller and
Matter of Harriet Bush; codification of Mercantile
2004-10
2004-09
2004-08
2004-07
2004-06
2004-05
2004-04
2004-03
2004-02
2004-01
2003
12/19/03 More changes on New York’s 529 Plan; intra-family loans: term and demand loans,
and forgiving them; note on William Roth and John Breaux
11/26/03 Inflation-adjusted numbers for 2004; charitable remainder trusts, “ordering rules”
and qualified dividends (REG-110896-98)
11/10/03 Connecticut “decouples” for a bit; New York and New Jersey “decoupling” –
disclaimers and contingent QTIPs; changes to New York’s 529 Plan
10/24/03 IRS acquiesces in Walton GRAT decision (Notice 2003-72); Social Security and “full
retirement age”
2003-21
2003-20
2003-19
2003-18
10/10/03 The Independent 529 Plan 2003-17
09/26/03 IRS guidance on reporting requirements for substitute dividends (Notice 2003-67);
the “Wall Street Rule”; tax reward money taxable (Roco)
2003-16
09/05/03 The fall legislative agenda; saving for a child’s college education 2003-15
Tax Topics – Table of Contents – 2013 – 8
08/06/03 Strangi III – the Tax Court thumps taxpayer in Texas FLP case 2003-14
07/23/03 7 th Circuit upholds IRS win in Hackl: no annual exclusion for gifts of LLC interests 2003-13
07/01/03 New York’s “tax traps” regarding the estate tax, GST and non-residents 2003-12
06/16/03 More on JGTRRA, qualified dividends and the new tax rates 2003-11
06/06/03 JGTRRA: lower rates, qualified dividends, increased child tax credit; marriage penalty
relief; increased AMT exemption; chart with phase-outs of the AMT exemption
amounts
05/16/03 Jobs and growth bill; trust’s investment fees subject to 2% floor (Scott); tax
apportionment (PNC Bank v. Roy); Michigan and the TPT credit (Lacks v. Michigan
Department of Treasury)
2003-10
2003-09
05/02/03 Jobs and growth bill; flat tax proposals; tax apportionment (Kuralt) 2003-08
04/11/03 Budget update; estate tax pitfalls for non-resident aliens (Fung); “indirect skips” and
the GST; QTIP election boo-boo (PLR 200314012); early CRUT termination and
capital gain (PLR 200314021)
03/28/03 Budget news; contingent attorneys’ fees (Raymond) – and how AMT interacts with
them
03/13/03 Budget and legislative update; marital deduction mess-up (Davis); limited education
no defense against estate tax deficiency (Koester)
02/28/03 Taxpayer’s SCIN works (Estate of Dulio Costanza); SCIN contrasted with private
annuity; IRS loses on “joint-spousal GRATs” (Cook)
02/14/03 Details on Fiscal Year 2004 Budget, including various proposed savings accounts
(lifetime, retirement and employer-sponsored); impact on 529 plans; a closer look at
arguments in favor of tax-free dividend proposal
01/31/03 State of the Union address and tax-free dividend proposal; CBO’s deficit numbers;
Sen. Daschle on the Democratic plan; is all retirement plan income “effectively” taxfree?
(KD 3761); “decoupling” in Nebraska and Kansas
01/16/03 President Bush’s job creation plan and tax proposals, including tax-free dividends;
Sen. Feinstein on freezing the top rate; JCT lists expiring provisions;House rules to
require macroeconomic analyses; dynamic scoring
2002
12/19/02 New faces: John Snow and Steven Friedman; adjustment clause too much like
Procter – Mom can’t take back gift (TAM 200245053); non-immigrant visa doesn’t
preclude domicile (Estate of Jack); payments to Holocaust survivors permanently
exempted from income tax
11/27/02 Our “abominable” tax code and how it got that way; Lindy Paull’s departure; how
7520 rates affect planning techniques – why GRATs work better with lower rates and
QPRTs don’t
2003-07
2003-06
2003-05
2003-04
2003-03
2003-02
2003-01
2002-22
2002-21
Tax Topics – Table of Contents – 2013 – 9
11/19/02 Aftermath of the mid-term elections and the AMT; estate tax issues; inflation-adjusted
numbers for 2003
10/25/02 Run-down on proposed legislation: the CARE and NESTEG bills; next year’s FICA;
low 7520 rates and planning: QPRTs, CLATs, CRATs, GRATs and charitable gift
annuities
09/20/02 Possible permanency of 2001 Tax Act and its education provisions;“decoupling”:
D.C., Massachusetts, New Jersey and New York
2002-20
2002-19
2002-18
09/04/02 Treasury ends “abusive” split-dollar scheme (Notice 2002-59) 2002-17
08/29/02 CBO’s budget numbers and stimulus proposals; IRA discussion correction – comment
from Cathy Vohs of the IRS
2002-16
08/01/02 CARE Act progresses – proposed gifts to charity from IRAs 2002-15
07/23/02 Corrections on IRA discussion; single life distribution table 2002-14
07/18/02 Corrected discussion on the final minimum distribution regs 2002-13
07/02/02 The debt limit increase; IRS retreats from imposing FICA or FUTA taxes on ISOs
(Notice 2002-47)
06/21/02 Attempts to make 2001 Tax Act permanent; efforts at estate tax reform; law-school
expenses not deductible (Galligan); ignorance of the law is no excuse – “innocent
spouse” relief denied (Mitchell)
2002-12
2002-11
05/24/02 The “sunset” provision of the 2001 Tax Act; new IRA distribution tables 2002-10
04/18/02 Thoughts on 529 Plans; IRS issues final rules on IRA distributions; “decoupling”:
Maryland, Nebraska and New York
04/09/02 Tax Court denies annual exclusion for gifts of LLC interests (Hackl); Florida says
goodbye to estate tax revenues
03/20/02 Senate Finance Committee hearing on tax shelters; Joint Committee on Taxation
report on shelters and judicial doctrines used against them
03/15/02 Stimulus bill passes; bill to freeze some of 2001 Tax Act; CBO and OMB revenue
projections; Concord Coalition suggestions about fiscal year 2003 budget; GRAT
includibility under IRC Sec. 2039 (TAM 200210009); Vermont “decoupling”; the GST
and “indirect” skips – the opt-out
02/28/02 Tax shelter amnesty (Announcement 2002-2); whither the corporate income tax?; IRS
permits early CRUT termination (PLR 200208039) and tax treatment of early
termination (PLR 200127023); IRS information on Victims’ Relief Bill (Publication
3920); New York City’s cigarette tax
02/22/02 President Bush’s fiscal year 2003 budget; Senate vote on estate tax repeal; the
shrinking surplus; increase in debt ceiling; taxability of frequent flyer miles
(Announcement 2002-18); cigarette taxes
2002-09
2002-08
2002-07
2002-06
2002-05
2002-04
Tax Topics – Table of Contents – 2013 – 10
01/31/02 Victims’ Relief bill signed – planning points; bill to reinstate marital deduction for noncitizen
spouses (H.R. 3575); the state death tax credit and “decoupling”: Minnesota,
Rhode Island and Wisconsin
2002-03
01/25/02 IRS Notice on split-dollar life insurance (Notice 2002-8) 2002-02
01/11/02 Tom Daschle speech on the economy; 2001 Report of the National Taxpayer
Advocate
2002-01
2001
12/21/01 The stimulus package; the Victims of Terrorism Relief Act; inflation-adjusted numbers
for 2002
11/30/01 More on Victims of Terrorism bill (history of prior such bills); applicability of FICA and
FUTA taxes to ISOs (incentive stock options): proposed regulations (REG-142686-01)
and Notices 2001-72 and 2001-73; the AMT and ISOs
11/26/01 Stimulus package stalls; Victims’ Relief bill progresses; 18% capital gains tax rate and
gain on principal residence exclusion (Revenue Ruling 2001-57)
10/31/01 More thoughts on the Victims of Terrorism relief bill; FICA increase; France and the
VAT
2001-25
2001-24
2001-23
2001-22
10/24/01 Stimulus plans; budget shortfalls in California, Florida, New York and North Carolina 2001-21
09/28/01 9/11 aftermath: Victims of Terrorism Relief Act 2001-20
09/04/01 More on “timing” and the new estate tax rates; the phase-out of the state death tax
credit
2001-19
08/07/01 AMT ISO relief?; “timing” and the new estate tax rates; the tax rebates 2001-18
08/02/01 Possible repeal of the “sunset” provision and the estate tax; GST “indirect” skips and
deemed allocations
2001-17
07/25/01 GST changes under 2001 Tax Act 2001-16
07/10/01 Two unfavorable IRA rulings: sons can’t be default “designated beneficiaries”
(PLR 2001260410) and daughter can’t name herself as Mom’s designated beneficiary