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Most Recent Posts

Who’s Afraid Of Bank Reporting To IRS?

Who’s Afraid Of Bank Reporting To IRS?

There is grounds to be skeptical that the IRS will get much out of the new information source.  In 2018 TIGTA reported that IRS was not taking advantage of currency reports generated under the terms of the oxymoronic Bank Secrecy Act.

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Part Of Build Back Better Could Be Disaster For Trust Owned Life Insurance

Part Of Build Back Better Could Be Disaster For Trust Owned Life Insurance

Take the case of an ILIT that is meant to take care of a special needs child after the parents are gone.  It is funded by a second to die life insurance policy.  If the second to die parent is leaving a nice house and some left over retirement funds, they might be close to or slightly whatever is then the federal threshold.   Pulling in a big piece of the special needs trust would be nasty

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S Corp To Partnership Conversion Under Build Back Better

S Corp To Partnership Conversion Under Build Back Better

If you and your sibling start a business with capital contributions, run it without debt, and don’t have other owners coming and going, there is a good chance that your individual returns will work out roughly the same whether the partnership or the S corporation form is used.  That is until one of you wants to be redeemed or, you know, dies while the other continues on.

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Time To Change Your Estate Plan – Again

Time To Change Your Estate Plan – Again

I sometimes think that the estate and gift tax system is actually a white collar jobs program for college graduates not quite smart enough to become physicians or engineers.  It redistributes wealth from the upper class to the upper middle class.  Too bad this is going to ruin the holidays for them.

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Trying To Get IRS To Shut Up About Conservation Easement Litigation

Trying To Get IRS To Shut Up About Conservation Easement Litigation

For purposes of section 6103 of the Code, a disclosure that does not name Mr. Clark still identifies him if it contains information that, combined with other information available at the time of the disclosure or that becomes available subsequently, permits persons generally knowledgeable with the relevant transactions and industry to identify Mr. Clark.

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IRS Hangs Tough On Conservation Easements

IRS Hangs Tough On Conservation Easements

What would be really equitable would be for the IRS to allow donors and land trusts to retroactively fix documents that fail the requirement.  The abusive syndicated conservations easements deserve to be crushed, but it should not be at the expense of legitimate deals.

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