Categories
Estate & Gift Tax Tax

Can Defective Deed Defeat IRS Estate Tax Lien?

The IRS lien is broad and attaches to the taxpayer’s property. Creative tax attorneys have tried to find ways around the lien with limited success. The recent Saccullo v. United States, No. 17-14546 (11th Cir. 2019) case raises the question as to whether a defectively executed deed be used to defeat the IRS’s estate tax […]

Categories
Federal Income Tax

The Private Trust Company

The IRS recently released Notice 2008-63 in advance of a formal Revenue Ruling. This Notice provides guidance on the federal tax implications of private trust companies and similar trust arrangements. Notice 2008-63 confirms that private trust companies generally do not result in any estate, gift, or generation skipping tax benefits that could not be realized […]

Categories
Federal Income Tax

Tax Basis Planning for Inherited Property

The gain from the sale property is subject to income tax.  Gain is generally the sales price minus tax basis, and tax basis is generally the cost or investment into the property.  When a person owns property at death and the property passes to the heirs, the heirs get a tax basis equal to the […]