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Revocations and Rejections

Tuesday, April 22, 2014

Among this week's release of private letter rulings were two rejection letters and one revocation, numbered PLRs 201416009 through 201416011.

May 7520 Rate Returns to 2.4%

Tuesday, April 22, 2014

Rates, Tables & Statistics

In Rev. Rul. 2014-13 Service announced the Section 7520 rate for May will return to 2.4%, up twenty basis points from the preceding two months.

Consolidated Estate and Tax Planning Update

Monday, April 21, 2014

At times, IRS issues rulings that are important to some charitable planners who also work in the estate planning and related tax planning fields. For those individuals, we include in this current event a listing to consolidate several rulings of potential interest. More information about these consolidated rulings, including the text, summary, extended summary, and commentary (as the case may be), is available for review through the links.

PLR 201416006 - Same Property May be "Parked" for Multiple Potential Like-Kind Exchanges

Monday, April 21, 2014

In PLR 201416006, the Service ruled a corporation could "park" a potential replacement property with an accommodation party in anticipation of closing a like-kind exchange, even though it was anticipated the property might instead by acquired by either of two affiliated corporations.

CCA 201416007 - No Marital Deduction for Unenforceable Portion of Elective Share

Monday, April 21, 2014

In CCA 201416007, a lawyer in the Chief Counsel's office determined an estate tax marital deduction would not be allowable for the portion of the surviving spouse's elective share that would have been satisfied from assets of a foreign trust. These funds were not, in fact, recoverable.

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