An update from time to time on various cases, private and public tax and nontax rulings and regulations by Ed Zollars and others - edited by Steve Leimberg and designed for tax professionals.
In this 8-minute podcast, Bob Keebler and Jason Early discuss the implications of the Tax Court's decision in Cavallaro v. Commissioner, T.C. Memo 2019-144 (10/24/2019). The Tax Court's Memorandum Opinion can be found at https://ustaxcourt.gov/UstcInOp/OpinionViewer.aspx?ID=12088 . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
In this 18-minute podcast Bob Keebler interviews attorneys David A. O'Neil and Anna Moody, who represented the taxpayer in North Carolina Department of Revenue v. The Kimberley Rice Kaestner 1992 Family Trust, decided by the United States Supreme Court on June 21, 2019. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
In this four-minute podcast, Bob Keebler and Professor Mitchell Gans discuss the implications of North Carolina Department of Revenue v. The Kimberley Rice Kaestner 1992 Family Trust, scheduled for oral argument before the United States Supreme Court this month. They suggest that certain taxpayers in North Carolina and states with similar laws consider filing claims for refund of income tax paid. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
In Avrahami v. Commissioner, 149 T.C. No. 7, the Tax Court held that amounts paid to a captive insurance company and an offshore reinsurer were not insurance premiums for federal income tax purposes and were not deductible under Internal Revenue Code section 162. Bob Keebler and Jay Adkisson discuss the decision and its implications. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
In this podcast, Bob Keebler discusses the implications of Rev. Proc. 2017-34, creating a simplified procedure to obtain an extension of time to file a portability election. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler and Jonathan Blattmachr This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
In CCA 201651013, the IRS Chief Counsel concludes that a trust is not entitled to claim a charitable income tax deduction despite a modification of the trust to permit charitable distributions. Bob Keebler reports. The full text of CCA 201651013 can be found at https://www.irs.gov/pub/irs-wd/201651013.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Rev. Proc. 2016-49 opens new opportunities in planning for the marital deduction. In this podcast, Bob Keebler discusses the available strategies for maximizing estate tax exemptions, protecting assets and preserving flexibility. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
In Estate of Barbara M. Purdue et al. v. Commissioner, T.C. Memo. 2015-249 (December 28, 2015), Tax Court Judge Goeke ruled favorably on the estate and gift tax aspects of a family limited liability company. In this podcast, Bob Keebler discusses the case and its implications for estate planning and administration with N. Todd Angkatavanich and James I. Dougherty. For a written analysis of the Purdue case, see LISI Estate Planning Newsletter #2374 (January 11, 2016). This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
In this podcast, Bob Keebler and Todd Angkatavanich discuss the basics of Internal Revenue Code section 2701, including: - How section 2701 relates to the rest of Chapter 14 - Application of the section to a broad scope of transactions - The "vertical slice" rule - Recapitalizations and CCA 201442053 - Planning opportunities. Recorded August 25, 2015. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
In PLR 201539021, the IRS granted an extension of time for an estate to claim portability. Michelle Ward reports. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
It is widely expected that the Treasury Department will, within the next few months, issue regulations under Code section 2704(b) limiting the ability to claim valuation discounts on transfers of interests in limited partnerships and other entities. In this podcast, Bob Keebler interviews Jonathan Blattmachr, who explains section 2704 and the existing regulations and case law and discusses the potential impact of new regulations. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
In Estate of Elkins v. Commissioner (9/15/2014), the Fifth Circuit Court of Appeals upheld a 45% valuation discount for fractional interests in works of art, reversing a decision of the United States Tax Court. In this podcast, Bob Keebler and Jonathan Blattmachr discuss the case and its implications for planning. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler interviews Edwin Morrow of Key Bank and Ohio attorney Bo Loeffler in an in-depth discussion of the implications of the U.S. Supreme Court decision in Clark v. Rameker for asset protection planning and income tax planning for IRAs. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler interviews Professor Mitchell M. Gans and Jonathan G. Blattmachr on the subject of the U.S. Tax Court's decision in Estate of Trombetta v. Commissioner, T.C. Memo. 2013-234. In Trombetta, the Tax Court held that rental properties transferred to an annuity trust were required to be included in the transferor's gross estate because the transfers to the trust were not bona fide sales for adequate and full consideration, and the transferor retained during her lifetime an interest in the transferred properties. Blattmachr and Gans have written an article on the case for the May, 2014 issue of the Journal of Taxation. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
The IRS has just released PLRs 201410001 through 201410010, approving a Nevada Incomplete Nongrantor (NING) Trust. In this podcast, Bob Keebler interviews Bill Lipkind, the attorney who obtained the ruling, and Steve Oshins, the attorney who handled the Nevada state law review. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
In Chief Counsel Advice Memorandum 201330033, the IRS concluded that a SCIN transaction by a taxpayer in poor health resulted in a taxable gift. Bob Keebler reports. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler and Mitchell Kitces discuss the very important Section 1035 Ruling. This is a really terrific and very practical interview you will not want to miss. Even if you don't ordinarily listen to PodCasts, listen to this one! This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler and George Karibjanian follow up on George's recent LISI commentaries on the impact of Windsor. Is it Equality for All or Only for Some? To understand the impact of Section 3 of DOMA, listen to this fascinating discussion. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Estate Planning after the American Taxpayer Relief Act of 2012 Video Presentation. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob interviews attorney Michael Goller who discusses the new Covered Opinion Proposed Regulations. This is a very important development focusing on Section 10.37 - dealing with tax opinions and how attorneys must comply. Also stressed in this interview is section 10.35, which requires competence and 10.36 dealing with management oversight proceedures and standards. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler and Keith Buck discuss the implications of Neff, an important new split dollar case. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler shares ideas on social security timing. Timing IS everything! This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler is joined by Jonathan Blattmachr and this dynamic duo discusses the facts and implications of this important new IRS ruling This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob speaks with Mike Gollar, a tax attorney about Taxpayer Penalties and how to avoid them. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler continues his incredible PodCast series with # 4 - Taxation of Put Options. Be sure to listen to Parts 1-3 as well. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Stars Bob Keebler and Jonathan Blattmachr discuss multiple planning tactics and considerations for this most important and pivotal year. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob chats with Jonathan Blattmachr about the property law aspects of decanting. Be sure to listen to the other Podcast where the two discuss the tax aspects. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler and Jonathan Blattmachr discuss what decanting is and how it is impacted by federal tax laws. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler teams up with Mike Jones to give LISI members the scoop on Roth Recharacterizations with Required Distributions. LISI wants to let you know about Bob's upcoming Two Day IRA Seminar for Lawyers, CPAs and Financial Advisors - ?What the Lawyer, CPA and Financial Advisor Need to Know About Sophisticated Planning and Drafting for IRA & Qualified Plan Distributions Including How to Plan with a $5,000,000 Exemption? The seminar provides extensive coverage regarding planning with retirement accounts including: Estate planning for IRAs with a $5,000,000 exemption, the Pension Protection Act, the IRA Regulations, pre-retirement issues, required beginning date issues, the inherited IRA, the minimum distribution rules, spousal rollovers, QTIPing an IRA, charitable bequest planning, beneficiary designation planning, retirement plans payable to trusts, Roth IRA issues, distribution of employer securities, insurance strategies and new, innovative planning strategies. Please contact Emily Rosenberg at 920.593.1705 or emily.rosenberg@keeblerandassociates for more information. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler, with years of experience in Roth Conversions, provides LISI members with his views of where things stand today and the opportunities and pitfalls. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler and Jonathan Blattmachr discuss potential portability of spouse's exemption issues and their solutions. Be sure to search our LISI Estate Planning Newsletters for more on this very important topic. Be sure to check-out the Keebler-Shenkman article for top malpractice mistakes. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler discusses the operation, traps, and tips regarding the 2010 Form 8939 and IRS form 706 with Vince Lackner of the Lackner Group. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler discusses Section 1092 Straddle Rules This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler and Vince Lackner of Lackner Group discuss the potentially serious malpractice traps involved with the new portability rules. Be sure to also listen to our PodCast featuring Bob Keebler and Marty Shenkman on this topic. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
How can a client reduce the potential tax burden where the holding in question is a large concentration of stock in one or two companies? Bob Keebler discusses Strategies for Mitigating taxation of concentrated low basis positions. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler discusses with Las Vegas attorney Steve Oshins recent proposals by the Obama administration that would impact significantly on estate tax laws and planning. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler and Marty Shenkman discuss possible malpractice issues with respect to portability. This is a VERY important message - one LISI suggests EVERY estate planning attorney and CPA listen to carefully! This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler discusses the 2011 Federal Estate Tax Return and Portability with Vince Lackner. Be sure to read Vince Lackner's commentary in LISI Estate Planning Newsletter # 1863. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Paul Hood discusses non-controlling normalizing adjustments. Don't miss Paul's upcoming 9/28 program at 12:00 P.M. EDT talk on Phil Cavesh?s Ultimate Estate Planner. It's A Method in the Madness: The Fine Art of Designing Estate Planning Tools and Techniques. To learn more or sign up: http://www.ultimateestateplanner.com/092811PH.html This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Paul Hood - Tax Affect or not Tax Affect S Corporation earnings? Paul Hood discusses the issues. Is there a premium? Should you believe the Tax Court? Keep listening. Paul Hood will be hosting a 90 minute teleconference on September 28th titled ?A Method in the Madness: The Fine Art of Designing Estate Planning Tools and Techniques.? On this special teleconference, Paul will cover how proper plan design is really a 3-part analysis (the technique, the particular assets and the ?players? involved), and how to balance ?asset? factors such as valuation issues, intended use and management of assets, ease of transfer or division, availability as loan collateral and special tax attributes. Register by calling 866.754.6477 or online using this link: Paul Hood Teleconference . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Business Valuation authority Paul Hood discusses valuation when a controlling interest in a closely-held corporation is involved. Paul is the co-author of a new book on business valuation - A Reviewer's Handbook to Business Valuation - that was the subject of our recent book review in Business Entities Newsletter # 127. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Paul Hood, co-author with Tim Lee of the recently published book, A Reviewer's Guide to Business Valuations, discusses recent cases involving valuation discounts for built-in capital gains. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Valuation authority, Paul Hood, discusses discounts for lack of marketability. Paul will be presenting, in conjunction with Phil Cavesh, a program called A Method in the Madness: The Fine Art of Designing Estate Planning Tools and Techniques. For information or to sign up: http://www.ultimateestateplanner.com/092811PH.html This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
In this important PodCast, Bob Keebler reviews what he is calling the Section 1022 Election/AMT 'Curveball.' According to Bob, it appears that there is a strong possibility that taxpayers electing carryover basis will have different basis for AMT and regular tax purposes. This, according to Bob, appears to have been missed by the tax writing committees and the IRS. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
In this PodCast, Bob Keebler reviews a variety of strategies that can immediately help clients with their stock and bond investments. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler discusses Revenue Procedure 2011-41, which was issued by the IRS on August 5th. Bob covers the safe harbor rules applicable when executors elect out of paying estate tax, as well as the rules on how-to allocate basis This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
In this PodCast, Bob Keebler focuses on Notice 2011-66, the 1022 election not to pay estate tax, along with impact of Form 8939 This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
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