Will Your 2012 Gift Tax Return be Audited by the IRS?

In 2012 taxpayers and their advisers were scratching their heads about the presidential election and its impact on future gift and estate tax exemptions because the $5 million inflation indexed per person federal estate and gift tax exclusion was scheduled to drop to $1 million on January 1, 2013. Consequently, many wealthy matriarchs and patriarchs …

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Qualified Personal Residence Trusts

GIFT YOUR RESIDENCE TO YOUR BENEFICIARIES DURING YOUR LIFETIME, CONTINUE TO RESIDE IN IT AND SAVE TAXES WHAT IS A QPRT? A qualified personal residence trust (QPRT) is a trust typically designed to transfer a primary residence (*) to your beneficiaries during your lifetime which, if you elect, permits you to serve as the trustee. …

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Estate & Gift Tax Valuations: Can the IRS Disregard an Agreed Upon Value for Shares in a Buy-Sell Agreement?

Section 2703 of the Internal Revenue Code enacted in 1990 states that buy-sell agreements are disregarded for valuation purposes, unless the agreement satisfies the following tests. Test One: The Agreement Must Constitute a Bona Fide Business Arrangement The buy-sell agreement (Agreement) cannot be a ploy to transfer shares to members of the family at a …

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The Importance of Gifting in 2012

Gary Ringel was recently featured as a guest on What About Wealth? Internet broadcast on August 7, 2012.  What About Wealth? is a live Internet radio program and syndicated podcast on VoiceAmerica Business Channel hosted by Rich Bloomfield and Rick Durfee.  The subject of the broadcast was the latest news on gifting opportunities and the …

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A Huge Taxpayer Win in Favor of Formula Clauses

A recent U.S. Tax Court case (Wandry v. Commissioner, T.C. Memo 2012-88, March 26, 2012) highlights the usefulness of formula clauses in gift transactions. The taxpayers, husband and wife, made gifts to their children and grandchildren of interests in a family limited liability company. Their tax attorney advised them to make all gifts as a …

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