In Notice 2023-54, 2023-31 I.R.B. ____ (7/31/2023), the Internal Revenue Service has provided some guidance on transition rules for both the changes made by the SECURE 2.0 Act of 2022 (Division T of the Consolidated Appropriations Act of 2023, P.L. … Continue reading
Category Archives: Rulings
In Rev. Rul. 2023-2, ___ I.R.B. ___, the Internal Revenue Service has held that assets held in an irrevocable trust that was a grantor trust do not receive a new basis under I.R.C. § 1014 on the death of the … Continue reading
The Internal Revenue Service has announced that the two-year period for filing an estate tax return merely to elect portability has been extended to five years from date of death. Rev. Proc. 2022-32, IRB 2022-30 IRB ___ (7/25/2022). In Rev. … Continue reading
A ninety year old woman suffering from dementia was unable to change her domicile, so her estate was not subject to inheritance tax even though her son had moved her from New York to an assisted living facility in Pennsylvania … Continue reading
The Internal Revenue Service has released Rev. Proc. 2018-57, 2018-49 I.R.B. ___ (12/3/2018), with the official inflation adjustments for 2019. The published adjustments for income taxes differ in many cases from the inflation adjustments that were published here in September, … Continue reading
The IRS has issued another private letter ruling granting retroactive tax effect to a judicial reformation of a trust which the IRS agreed did not carry out the intentions of the settlor due to an error by the attorney who … Continue reading
The IRS has issued five identical private letter rulings, PLRs 201442042, 201442043, 201442044, 201442045, and 201442046, apparently to five different parties involved in the same transaction, agreeing that a court-approved reformation of a trust in accordance with § 415 of...
The IRS has issued five identical private letter rulings, apparently to five different parties involved in the same transaction, confirming that a court-approved reformation of a trust in accordance with § 415 of the Uniform Trust Code would be respected … Continue reading