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What is is an online tool for planning professionals seeking to manage their research, save time and make educated decisions. In addition to a fully searchable library, useful calculations and personal file management, subscriptions include daily commentary from our team of experts on important events, as well as access to the definitive Handbook on the field of Charitable Planning.

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Current Events in the Charitable World

Monday, October 20, 2014

Federal tax law applicable to charitable gift planning is essential knowledge for all gift planners. Advanced gift planners need timely and accurate information on technical, judicial and regulatory actions affecting their work. This speech, given on October 15th at the 2014 National Conference on Philanthropic Planning in Anaheim, covers relevant new IRS rulings, Treasury actions and regulations, and court decisions. Congressional developments will also be considered.

PLR 201442003 - Late Section 754 Election

Monday, October 20, 2014

In PLR 201442003, the Service exercised its discretion to allow a late election to adjust the inside basis of a decedent's interest in a limited liability company taxed as a partnership.

PLR 201442047 - Late ESBT Election

Monday, October 20, 2014

In PLR 201442047, the Service granted inadvertent termination relief to an S corporation where the trustee of an irrevocable inter vivos trust failed to make a timely ESBT election.

PLR 201442017 - Substantial Compliance in Allocating GST Exemption

Monday, October 20, 2014

In PLR 201442017, the Service ruled that a transferor had substantially complied with statutory requirements for allocating unused GST exemption to transfers to two irrevocable trusts.

Split Rulings on Late Form 8939 Filings

Monday, October 20, 2014

In PLR 201442015, the Service rejected an executor's request to extend the time for filing Form 8939, to elect out of the retroactively reinstated estate tax for a decedent who died in 2010, and instead to allocate up to $1.3 million in basis increase to selected assets.

In PLR 201442019, the Service exercised its discretion to allow an executrix to refile a Form 8939, which was filed late.

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