Successful defense to an IRS section 2036(a) attack: estate of E. Stone III

Article Abstract:

The IRS has been trying to rein in family limited partnerships and family limited liability companies ever since the Rev. Rul. 93-12 came into effect because of abuse of certain provisions in the rule. Tax planners seized on the opportunity to transfer real estate assets to a FLP or a family limited liability company, thereby reducing the value of interests in the transferred entity.

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Navigating a one-way street: merging with disregarded entities under the new Temporary Regulations

Article Abstract:

The reason for the enactment of the Temporary Regulations and the way in which they came into effect are examined. The tax planning opportunities, which are available to taxpayers as a result of the publication of Temporary Regulations are explained through a series of examples.

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The new tax shelter disclosure and investor list regulation

Article Abstract:

To regulate abusive tax avoidance transactions, Treasury and Internal Revenue Service (IRS) is revising the categories of transactions that disclosed under Temp.Reg. 1.6011 -4T. Six categories of transactions to maintain investor lists are presented.

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