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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.
PLR 201416001 - Modification of "Grandfathered" GST Exempt Trust
Monday, April 21, 2014
In PLR 201416001, the Service ruled favorably on the proposed judicial modification of a pre-1985 multi-generational testamentary trust.
Judicial Watch FOIA Suit Yields Hundreds of Lerner e-Mails
Friday, April 18, 2014
IRS finally released hundreds of documents in connection with the (c)(4) controversy, as a result of a Freedom of Information Act lawsuit brought by Judicial Watch. Some emails within this group were between former EO Director Lois Lerner, other IRS officials, and the Department of Justice, discussing the possible prosecution of 501(c)(4) organizations, who had falsely stated on their applications that their political activity would be minimal.