KYEstates brings you PLR 200945011 (Nov. 6, 2009), a Letter Ruling that KYEstates can’t quite bring itself to really love, even though Natalie Choate surely does. The Letter Ruling has both good news and bad news for taxpayers. First, the good news: under the facts of the Letter Ruling, lump-sum, immediate income in respect of […]
Mike Bonasera of The Ohio Trust & Estate Blog graciously wrote a post about KYEstates after my telephone conversation with him today. Mike is a great guy who was really generous with his time, and full of helpful, specific suggestions for making KYEstates the best possible resource for the Kentucky T&E Community.
PLR 200944002 (Oct. 30, 2009) is an interesting development at the intersection of estate planning and asset protection planning. The widely accepted back story to the Letter Ruling is that it relates to Alaska asset protection trusts, a topic dear to the hearts of renowned T&E leader Jonathan Blattmachr and his brother Doug, who just […]
The Petter case recently analyzed by KYEstate$ noted that valuation discounts are “a major goal . . . of contemporary estate planning” because they often “create the possibility of a more taxpayer-friendly valuation.” Petter cautioned, however, that valuation discounts are “often a major problem.” It’s not surprising that the IRS would see valuation discounts as […]
You never know what will happen when the mainstream press tries to cover estate planning. Sometimes, good intentions go astray. Other times, many column inches provide relatively little insight. Once in a while, something useful is shared with the general public. KYEstate$ isn’t sure what to make of this New York Times article from February 18: […]
KYEstates strives to provide fair and balanced commentary. No, truly, we do. Image: U.S. Tax Court Website So, when we are biased, we’ll let you know. Please be advised that KYEstates is biased in favor of the taxpayer. For that reason, KYEstates is happy to report on the facts, arguments, and taxpayer victory in Estate of […]
T&E Community – in the midst of all the estate planning you do for your clients, do you ever pause for a moment to wonder whether your own retirement planning is in order? At the Notre Dame Estate Planning Institute last October, in between opportunities to catch up with Kentucky T&E attorneys Jesse Mountjoy of […]
Will the estate tax, like an old soldier, fade away? Or, like the same old soldier, will it return? The FY2011 Green Book, recently published by our friends in Washington, shows they are planning for the tax to return. The transfer tax sections of the FY2011 Green Book are looking awfully similar to what we […]
You were not needing your morning cup of coffee to stay awake while reading this New York Times article last week featuring George Cloutier. The article’s title says it all: “Fire Your Relatives. Scare Your Employees. And Stop Whining. ” If the reporter on the story, Kermit Pattison, hasn’t considered law as a “Plan B” career […]
Since late December, when it first appeared that estate tax repeal would actually happen, estate planners nationwide have been discussing its potential negative consequences. Consider this fact pattern: a second marriage, and a normal A-B estate plan. The plan uses a formula allocation clause directing the greatest amount of assets that can pass free of estate […]
He wanted nothing less of Daisy than that she should go to Tom and say: ‘I never loved you.” After she had obliterated four years with that sentence they could decide upon the more practical measures to be taken. One of them was that, after she was free, they were to go back to Louisville […]
The IRS has published Notice 2010-19 (IRB 2010-7, Feb. 16, 2010). The Notice provides guidance on the effect of IRC Section 2511(c). Section 2511(c), enacted as section 511(e) of EGTRRA in 2001, and amended by section 411(g)(1) of the Job Creation and Worker Assistance Act of 2002, provides that “a transfer in trust shall be […]