Splitting Up Family Assets Can Raise Estate Taxes
The thing I wonder about is whether the planning might have worked if rather than enhancing the Trust’s ownership in CI LLC, it had been slightly diluted. If the Trust’s interest were cleanly below 50%, higher discounts should have held up. The terms of the loan negotiated strike me as over the top, but with less than 50% ownership, the Trust would not be in a position to force distributions. The deficiency was over $58,000,000 which seems like it would have given the next generation quite an incentive to hang in for a little longer.
IRS Encourages CPA To Take Up New Trade
In a Final Agency Decision, the Administrative Judge (ALJ) disbarred Tiongson on March 1. The ALJ found that Tiongson’s advice to clients to use Form 2555 to treat California earned income as foreign source income on at least fifty-two tax returns, constituted disreputable conduct under Circular 230, and his failure to research the legitimacy of the filing position specifically violated the Circular’s due diligence standards.
Follow Me
Over and over again courts have said that there is nothing sinister in so arranging one’s affairs as to keep taxes as low as possible. Everybody does so, rich or poor; and all do right, for nobody owes any public duty to pay more than the law demands: taxes are enforced exactions, not voluntary contributions. To demand more in the name of morals is mere cant.