President Abraham Lincoln. Civil rights activist Martin Luther King, Jr. Rock guitarist Jimi Hendrix. Eccentric billionaire Howard Hughes. Singer/songwriter Bob Marley. NFL quarterback Steve McNair. Singer/songwriter Prince. What do these famous people
By Julie Frey Discounts for gifts of closely held business interests to family members may be significantly restricted soon. On August 2, 2016, the Internal Revenue Service issued new Proposed Regulations under Section
By Jason Palmisano The IRS has issued a notice of proposed regulations to limit the valuation discounts individuals have been afforded when they engage in certain types of intra-family transfers involving their
By: Amanda Wilson For a discussion of the five things you need to know now about the new partnership audit rules, please read my recent article found here.
By Jason Palmisano Stephen Martin wrote an interesting article in The Atlantic magazine arguing for bolstering the U.S. federal estate tax as it “is a policy that actually aligns neatly with the
By: Amanda Wilson The IRS recently released IRS legal memorandum 201606027. In this memorandum, the IRS considered the impact of a bad boy guarantee on allocating partnership liabilities under Section 752. Traditionally,
By: Amanda Wilson The Foreign Investment in Real Property Tax Act (FIRPTA) subjects foreign sellers to U.S. tax when they sell their interest in real property located in the U.S., including interests in