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Estate Taxes

Reminder: Mar. 31 is deadline for many inherited property basis returns

Reminder: Mar. 31 is deadline for many inherited property basis returns

The due date for filing returns with IRS and providing statements to beneficiaries under the rules requiring consistent basis reporting for inherited property for estate tax and income tax purposes, where the estate tax return of the decedent was filed after July 31, 2015, is Mar. 31, 2016, except with respect to decedents that died very […]

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Federal Circuit upholds reg imposing FICA tax liability on full value of deferred comp

Federal Circuit upholds reg imposing FICA tax liability on full value of deferred comp

Balestra, Jr. v. U.S., (CA Fed Cir 10/13/2015) 116 AFTR 2d ¶2015-5328 The Court of Appeals for the Federal Circuit has affirmed a lower court decision denying a retiree’s claim for a refund of FICA taxes paid on the full value of deferred compensation that he didn’t and will never receive as a result of […]

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U.S. House Passes Estate Tax Repeal Despite Veto Threat

U.S. House Passes Estate Tax Repeal Despite Veto Threat

WASHINGTON (Reuters) – The U.S. House of Representatives on Thursday ignored a White House veto threat and passed legislation to repeal the estate tax that hits inherited assets worth $5.4 million or more. By a mostly partisan 240-179 vote, the Republican-backed bill will be sent to the Senate, where Democrats are expected to use procedural […]

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What You Need to Know About Death and Taxes – Few Families Face Estate Taxes at All

What You Need to Know About Death and Taxes – Few Families Face Estate Taxes at All

What You Need to Know About Death and Taxes – Few Families Face Estate Taxes at All, as reported in the WS Journal. Q:How much can I get taxed if I was left a bank inheritance from my mother of $76,000, or split between me and my sister? T.J., Philadelphia A:Without knowing all the details […]

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Booming stock market puts spotlight on zeroed-out Grantor Retained Annuity Trusts (GRATs)

Booming stock market puts spotlight on zeroed-out Grantor Retained Annuity Trusts (GRATs)

Grantor retained annuity trusts, or GRATs, have been used by high wealth individuals to save transfer tax. In some cases, individuals have been able to structure GRATs in such a way that substantial amounts of wealth can be transferred to family members at zero estate or gift tax cost. This may be especially true for […]

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More Americans Are Writing Their Pets Into Their Wills

More Americans Are Writing Their Pets Into Their Wills

More Americans Are Writing Their Pets Into Their Wills – Leaving Thousands of Dollars for the Care of Animals, as reported in the news of the WS Journal. The number of Americans owning pets is at a record high, and more people are making provisions in their wills to provide for these animals after they’re […]

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Tax Court rules on various concepts used to value LLC interest

Tax Court rules on various concepts used to value LLC interest

In Estate of Tanenblatt v. Commissioner, T.C.. Memo. 2013-263, the Tax Court has ruled on various concepts involved in valuing a decedent’s LLC interest, including the effect of a clause in the LLC agreement that restricted the transferability of the interest. Background. Code Sec. 2038(a) includes in a decedent’s gross estate the value of all […]

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Decedent’s lifetime transfers of residence and rental properties includible in her estate

Decedent’s lifetime transfers of residence and rental properties includible in her estate

In Estate of Trombetta v. Commissioner, TC Memo 2013-234, the Tax Court has ruled that a taxpayer’s lifetime transfers of her residence to one trust and rental properties to another trust were transfers with a retained life estate and thus the properties were includible in her gross estate. It also ruled against the taxpayer with […]

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Why Your College-Age Children Need an Estate Plan They Should Designate Someone to Make Medical and Financial Decisions

Why Your College-Age Children Need an Estate Plan They Should Designate Someone to Make Medical and Financial Decisions

As reported in the WS Journal, Why Your College-Age Children Need an Estate Plan – They Should Designate Someone to Make Medical and Financial Decisions.  Here’s an issue many families overlook when children leave for college: That child, in the eyes of the law, is now an adult—and needs some all-important documents. Once individuals reach […]

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Marchex Berlusconi masterminded tax evasion plan, Italian court says

Marchex Berlusconi masterminded tax evasion plan, Italian court says

As reported in Reuters, former Prime Minister Silvio Berlusconi was the mastermind behind a complex system of tax evasion by his holding company Fininvest, Italy’s highest appeals court said on Thursday. The Court of Cassation, which published the reasons for its decision earlier this month to uphold Berlusconi’s conviction for tax fraud, pulled no punches […]

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Court won’t dismiss action against transferee for her father’s unpaid estate tax

Court won’t dismiss action against transferee for her father’s unpaid estate tax

A district court, in U.S. v. Mangiardi (DC Fl, July 19, 2013), 112 AFTR 2d ¶ 2013-5108, has refused to dismiss a transferee liability action brought by IRS against a decedent’s daughter, who had received funds from his IRA after his death. Facts. Joseph L. Mangiardi (Decedent) died on April 5, 2000. Maureen G. Mangiardi, […]

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Permanent rules make elimination of estate tax unlikely but some tweaking could occur

Permanent rules make elimination of estate tax unlikely but some tweaking could occur

A recently issued Congressional Research Service (CRS) report explains the permanent changes made to the estate and gift tax rules by the American Taxpayer Relief Act of 2012 (2012 Taxpayer Relief Act). While it notes some concerns that have been raised with respect to the estate tax, the CRS report expects the tax to remain […]

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Gift Tax Rules Allow For Plenty of Giving – Avoid Pitfalls In Estate Planning

Gift Tax Rules Allow For Plenty of Giving – Avoid Pitfalls In Estate Planning

Editor’s Note:  two concise and accurate responses to questions were provided in the LA Times article by Liz Weston, and I thought it would be worth repeating at this point since the subject comes up quite often.  Here’s the article. Dear Liz: My husband and I have given our daughters gifts over the years, but […]

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Form 706 for 2012 has new sections for portable exclusion and protective refund claims

Form 706 for 2012 has new sections for portable exclusion and protective refund claims

Editor’s Note:  IRS has released the final version of Form 706, United States Estate (and Generation-Skipping Transfer) Tax Return for estates of decedents dying after Dec. 31, 2011 and before Jan. 1, 2013, and its accompanying instructions. They reflect law changes made by the Tax Relief, Unemployment Insurance Reauthorization and Job Creation Act of 2010 […]

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Court finds FLP was formed despite incomplete documents and awards big refund to estate

Court finds FLP was formed despite incomplete documents and awards big refund to estate

The Court of Appeals for the Fifth Circuit, affirming a district court, has determined in Thomas Lane Keller, et al., v. U.S. (CA 5th Cir., 2012) (a complete copy of the opinion is here), that a decedent capitalized a family limited partnership (FLP) before her death, notwithstanding that she hadn’t completed certain documents. This resulted […]

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Be Ready for Higher Capital-Gains Tax Rates

Be Ready for Higher Capital-Gains Tax Rates

A very timely and newsworthy article appeared in the WS Journal, entitled “Be Ready for Higher Capital-Gains Tax Rates.”  After you read the article, ask yourself if you’ll ready once Congress makes a decision.  Here’s the article. When it comes to incurring taxes on your investments, it often pays to procrastinate.  But with long-term capital-gains […]

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Estate may be liable for increases to decedent’s foreign trust reporting penalties Chief Counsel Advice 201208028

Estate may be liable for increases to decedent’s foreign trust reporting penalties Chief Counsel Advice 201208028

Estate may be liable for increases to decedent’s foreign trust reporting penalties Chief Counsel Advice 201208028 In Chief Counsel Advice (CCA), IRS has determined that, because a decedent failed to file Forms 3520 and 3520-A with respect to a foreign trust he created, his estate became liable to pay Code Sec. 6677 initial and additional […]

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Is my inheritance safe? Can the IRS seize it? Recent Case says maybe, . . .

Is my inheritance safe?  Can the IRS seize it?  Recent Case says maybe, . . .

Editor’s Note: one question that comes up from time to time is the client who states they have been contacted by the IRS and the IRS wants the “inheritance” they received to be returned to the IRS. In some cases, the IRS has seized the asset in question.  In others, we fight the battle in […]

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Mitigation provisions didn’t allow a taxpayer an NOL discovered on audit Chief Counsel Advice 201208027

Mitigation provisions didn’t allow a taxpayer an NOL discovered on audit Chief Counsel Advice 201208027

Mitigation provisions didn’t allow a taxpayer an NOL discovered on audit Chief Counsel Advice 201208027 In Chief Counsel Advice (CCA), IRS has concluded that the mitigation provisions under Code Sec. 1311 through Code Sec. 1314 didn’t allow a barred refund after an audit resulted in an increased net operating loss (NOL) that was properly carried […]

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Ninth Circuit Court of Appeals Case Alert: Estate could only deduct amount it settled to pay income taxes, not higher projected amount

Ninth Circuit Court of Appeals Case Alert: Estate could only deduct amount it settled to pay income taxes, not higher projected amount

In the recent case of Marshall Naify Revocable Trust, (CA 9 2/15/2012) 109 AFTR 2d ¶ 2012-465, the Court of Appeals for the Ninth Circuit, affirming a district court, has held that an estate could not deduct a projected amount of a claim for state income tax because the tax liability was not ascertainable with […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney