Blanche Lark Christerson
Managing Director, Senior Wealth Planning Strategist
Tax Topics
Table of Contents
2013
2013
12/20/13 Budgets, tax reform and “extenders”; end of the year round-up 2013-12
11/15/13 The government shutdown, and selected inflation-adjusted numbers for 2014 and
end-of-the-year planning points
2013-11
10/07/13 A review of basic planning points 2013-10
08/30/13 Revised discussion of Windsor, reflecting guidance from the IRS and the Treasury
Department, issued on August 29, 2013
08/28/13 United States v. Windsor: the Supreme Court rejects Section 3 of DOMA, which
defines “marriage” as only between a man and a woman
07/01/13 Selected planning points: the now “permanent” $5 million exclusion, indexed for
inflation, state estate taxes and “portable” spousal exclusions
2013-09
2013-08
2013-07
05/29/13 Updated discussion of selected options to save for a child’s college education 2013-06
04/29/13 Selected tax provisions from President Obama’s Fiscal Year 2014 Budget 2013-05
03/21/13 Updated estate planning glossary and selected income tax terms 2013-04
02/20/13 Conservation easement flunks as charitable contribution (Belk); “DD” and the cost of
employer-provided health care; two important 100-year anniversaries; some lesserknown
provisions of the American Taxpayer Relief Act
01/25/13 Selected numbers from official IRS 2013 inflation-adjustments (Rev. Proc. 2013-15);
façade easement has zero value as charitable deduction (Scheidelman)
2013-03
2013-02
01/10/13 Selected overview of the “American Taxpayer Relief Act of 2012” (H.R. 8): 2001 and
2003 tax cuts largely made permanent, but higher taxes for the top 1% to 2%
2013-01
2012
12/31/12 Proposed regulations on the 3.8% tax on “net investment income”; Wandry again, and
how many gift tax dollars the “defined value” clause saved
11/30/12 The “fiscal cliff,” alternative minimum tax and transfer taxes; IRS “non-acquiesces” in
Wandry; possible taxpayer relief for those affected by Hurricane Sandy
10/31/12 Countdown to the election; selected 2013 inflation-adjusted numbers and various
planning points; Wandry appeal withdrawn
09/25/12 The looming “fiscal cliff” and the shape of possible future tax legislation; how NOT to
substantiate a charitable deduction (Mohamed v. Commissioner); Wandry appealed
2012-09
2012-08
2012-07
2012-06
07/31/12 The Supreme Court’s health care decision: The Affordable Care Act upheld 2012-05
06/11/12 Wandry v. Commissioner: yes, another taxpayer victory using a “defined value”
formula clause – but caution may be in order
04/19/12 Supreme Court arguments on the health care law; Medicare taxes taking effect in
2013: 0.90% on the wages of “high earners” and 3.8% tax on “net investment
income”; the Buffett Rule and the “Paying a Fair Share Act” (S. 2230)
03/08/12 Tax proposals on “high-income” taxpayers from President Obama’s Fiscal Year 2013
Budget and the Treasury Department’s “Green Book”
01/23/12 Estate of Petter v. Commissioner: another taxpayer victory using a “defined value”
formula clause, and the legacy of Procter v. Commissioner
2012-04
2012-03
2012-02
2012-01
2011
12/02/11 “Super Committee” bows out; 2012 inflation-adjusted numbers and various planning
points; the “Sensible Estate Tax Act of 2011” (H.R. 3467)
10/21/11 The American Jobs Act of 2011: the 28% limitation, the millionaires’ surtax, and the
“Buffett Rule”
09/16/11 The Budget Control Act of 2011 (Pub. L. 112-25) and the “Super Committee”: reduce
the deficit – or else!
07/28/11 How certain discretionary language almost made a credit shelter trust taxable in the
trustee/beneficiary’s estate (Estate of Chancellor v. Commissioner)
06/13/11 A Tax Court valuation case that illustrates just how far apart the experts can be, and
how a judge evaluates those experts (Estate of Mitchell)
05/03/11 Additional thoughts on last December’s 2010 Tax Act: lifetime gifts (GRATs, Sales to
Defective Grantor Trusts and QPRTs) and how “credit shelter trusts” are still relevant
despite the “portability” of a deceased spouse’s estate tax exclusion
2011-09
2011-08
2011-07
2011-06
2011-05
2011-04
Tax Topics – Table of Contents – 2013 – 2
04/06/11 What it means to be a “statutory resident” of New York for income tax purposes – and
how expensive that can be (Matter of Baker)
2011-03
02/24/11 Updated “estate planning glossary” 2011-02
01/31/11 A discussion of “tax expenditures” and possible tax reform, based on reports from the
President’s Deficit Commission and the National Taxpayer Advocate
2011-01
2010
12/23/10 Overview of the Tax Relief, Unemployment Insurance Reauthorization, and Job
Creation Act of 2010 (Pub. L. 111-312): income tax and capital gains rates, tax-free
distributions from IRAs to charity; estate and gift tax and GST provisions
11/30/10 Thoughts on the mid-term elections, and selected year-end planning points, along
with some of the inflation-adjusted pension plan numbers for 2011; brief reminder of
what low interest rates mean for certain planning techniques, including GRATs
(grantor retained annuity trusts) and Sales to Defective Grantor Trusts
10/26/10 Estate of Tatum: another disclaimer gone awry – but taxpayer loses this time;
possible timeline for retroactive reinstatement of estate tax and GST, based on
Carlton, a 1994 Supreme Court estate tax case
09/14/10 Taxpayer successfully rescinds defective disclaimers and avoids significant gift tax
liability (Breakiron); discussion of Bosch, the vintage case addressing when a state
law holding is binding on the IRS
07/27/10 A discussion of next year’s likely return of “PEP” and “Pease” (indirect tax increases
on higher earners) and the potential impact on charitable giving; two cases involving
purported charitable gifts and a skeptical IRS: Hendrix and Free Fertility Foundation
07/01/10 A round-up of the still uncertain tax landscape: Sen. Bernie Sanders’ estate tax bill
and its revenue raisers (consistent basis reporting, limits on valuation discounts and
GRAT restrictions), “PAYGO” and Sen. Kyl’s estate tax proposal; Rep. Ryan’s
“Roadmap”; NY drops “privity” requirement for executor’s suit against estate planning
attorney (Schneider v. Finnman)
05/28/10 “Pierre II”: the Tax Court addresses the “step transaction doctrine” and valuation
issues in a continuation of the Pierre v. Commissioner saga; valuation of fractional
interests used in QPRTs (Ludwick v. Commissioner)
2010-11
2010-10
2010-09
2010-08
2010-07
2010-06
2010-05
05/06/10 An updated discussion of some of the options to save for a child’s college education 2010-04
04/05/10 An overview of some of the provisions in the new health care legislation, particularly
the new Medicare taxes; codification of “economic substance doctrine”; GRAT
restrictions advance
02/28/10 President Obama’s FY 2011 Budget – increases on higher earners, and estate and
gift tax proposals: return to the 2009 estate tax regime, consistent values, modifying
rules on valuation discounts and mandating minimum 10-year term and remainder
interest for GRATs; under the “check-the-box” regulations, is a single member LLC
disregarded for gift tax purposes? (Pierre v. Commissioner)
2010-03
2010-02
Tax Topics – Table of Contents – 2013 – 3
01/26/10 The 2010 planning landscape: NO estate tax, GST or basis adjustment rules; what
Congress may do; possible constitutional “due process” challenge; what can go
wrong when documents are wrong about how property is titled (Beudert-Richard v.
Richard)
2010-01
2009
12/22/09 The imminent demise of the estate tax? Possible effect on formula provisions and the
difficulties of modified carryover basis; extenders bill and carried interest; proposed
stock transactions tax; importance of keeping beneficiary designations current
(Kennedy v. DuPont SIP)
09/30/09 More on Roth IRA conversions: calculating what the taxable amount may be; how a
“decoupled” state may tax a non-resident’s property, even if it’s passing to a surviving
spouse; NY advisory opinion on non-resident’s proposed condo purchase (TSB-A-
08(1)M)
08/31/09 What may happen with estate tax repeal and tax-free IRA distributions to charity;
early 2009 AMT “patch”; Roth IRA conversions in 2010 – restrictions will be gone so
that anyone may convert a “regular” IRA to a Roth
07/28/09 Some pros and cons of several options to pay for health care reform; the case of the
“tainted witness” and a will’s tax apportionment clause (Estate of Wu); how some
states are dealing with economic adversity
06/15/09 OMB’s “Analytical Perspectives” and Treasury Department’s “Green Book” offer
insights on Obama tax proposals and outline of estate and gift tax proposals:
consistent values, modifying rules on valuation discounts and minimum 10-year terms
for GRATs; taxing employer-provided health care?; new mortality tables and QPRTs;
New York’s increased taxes and estimated tax payments
04/20/09 The “Taxpayer Certainty and Relief Act of 2009” (S. 722) – makes lower income tax
rates permanent, increases higher rates, and freezes the estate tax at 2009 levels;
focus on whether Congress might reinstate the state death tax credit; new task force
on tax reform
03/19/09 President Obama’s FY 2010 budget proposal: higher rates, limits on itemized
deductions and the personal exemption phase-out; the interaction of the regular tax
with the AMT; historical income tax and capital gains tax rates; S. 394 would enhance
the tax treatment of art and collectibles
02/09/09 Rep. Pomeroy’s estate tax bill (H.R. 436); basic planning points; basis adjustment
rules, including modified carryover basis in 2010; “The Rangel Rule” (H.R. 735); intrafamily
loans
01/12/09 Suspension of 2009 required minimum distributions under The Worker Retiree and
Employer Recovery Act of 2008 (Pub. L. 110-458); a brief mention of another “bad
facts” limited partnership case (Hurford)
2009-10
2009-08
2009-07
2009-06
2009-05
2009-04
2009-03
2009-02
2009-01
Tax Topics – Table of Contents – 2013 – 4
2008
12/02/08 Prospective tax increases and their possible revenue implications; inflation-adjusted
numbers for 2009 and selected planning points
11/04/08 The Emergency Economic Stabilization Act of 2008 (Pub. L. 110-343): AMT
extenders and ISO relief, tax-free IRA distributions to charity, deduction for state and
local sales taxes, broker basis reporting, and harmonizing preparer penalties for
undisclosed positions; making lemonade out of lemons – coping with the market
decline
09/30/08 A discussion of the upcoming $3.5 million estate tax exclusion, and how it affects
planning in “decoupled” states, especially for married couples
08/29/08 A selected review of major tax legislation during the Bush administration, and a
snapshot of the tax proposals of Senators McCain and Obama
07/31/08 No discount for “restricted management accounts” (Rev. Rul. 2008-35); final regs on
“grantor retained interest trusts” (T.D. 9414)
06/30/08 Charitable remainder trusts and UBTI: final regs (T.D. 9403); charitable lead trusts
and “tiering” provisions: proposed regs (REG-101258-08)
05/30/08 Supreme Court holds that muni bonds still tax free (Kentucky v. Davis); IRS issues
proposed regs on alternate valuation (REG-112196-07; Kohler v. Commissioner)
04/28/08 The awful AMT and its disappearing exemption; Notice 2008-22 and a trust grantor’s
“nonfiduciary” power to swap trust property for property of equivalent value; planning
techniques that work well in a low-interest rate environment
2008-11
2008-10
2008-09
2008-08
2008-07
2008-06
2008-05
2008-04
03/31/08 Disclaimers and self-adjusting valuation clauses (Christiansen) 2008-03
02/26/08 More on the new preparer penalties: Notice 2008-13 2008-02
01/28/08 Supreme Court affirms that trust investment advisory fees subject to 2% floor
(Knight); wash sale rules and IRAs; survivorship and the marital deduction (Lee)
2008-01
2007
12/21/07 AMT patch, cont’d.; 11 th Circuit reverses Tax Court: built-in capital gains tax
liability reduces value of closely held corporation: Estate of Jelke (General Utitilies
doctrine; willing buyer-willing seller; IRA implications)
11/20/07 AMT patch; inflation-adjusted numbers for 2008 and planning points; 0% rate for
dividends and capital gains
10/26/07 Preparer penalties: the new rules under the Small Business and Work Opportunity
Act of 2007; transition rules under Notice 2007-54
2007-12
2007-11
2007-10
09/28/07 Charlie Rangel’s proposal; AMT and estimated tax; taxing “carried interest” 2007-09
08/31/07 Saving for college: the “kiddie tax” and the pros and cons of different savings vehicles 2007-08
Tax Topics – Table of Contents – 2013 – 5
07/31/07 Davis v. Kentucky Revenue Department – Supreme Court to examine muni bond
taxability; proposed regs on trust investment fees and the 2% floor (REG-128224-06)
06/28/07 Proposed regs on grantor retained income trusts (REG-119097-05); why timing of
payments matters; why there’s a 7520 rate; Rudkin update
05/31/07 “Kiddie tax” changes; custodial accounts; “pay-go”; whither the estate tax; get a good
valuation expert! (Kimberlin)
2007-07
2007-06
2007-05
04/27/07 2 nd Circuit affirms that trust investment fees subject to 2% floor: Rudkin 2007-04
03/29/07 IRS Clarification: non-spousal rollovers and tax-free IRA distributions to charity
(Notice 2007-7); tax patents; Chuck Grassley on the AMT and the “tax gap”
2007-03
02/28/07 Estate Planning Glossary 2007-02
01/30/07 The “First 100 Hours”; President Bush’s health care proposals; 2006 Annual Report of
the National Taxpayer Advocate
2007-01
2006
12/29/06 The Tax Relief and Health Care Act of 2006 (Pub. L. 109-432): “extenders”; health
savings accounts; AMT refundable credit; charitable remainder trusts and UBTI;
permanent capital gain treatment for self-created musical works
2006-11
11/22/06 The mid-term elections; 2007 inflation-adjusted numbers 2006-10
10/23/06 More on the Pension Protection Act of 2006: fractional interest gifts and $100,000 taxfree
IRA contributions to public charities; Charlie Rangel and AMT reform;
Connecticut marital deduction for same-sex couples
09/08/06 The Pension Protection Act of 2006 (Pub. L. 109-280): selected retirement and
charitable provisions
07/31/06 Estate Tax and Extension of Tax Relief Act of 2006 (H.R. 5970); Illinois decoupling
(McGinley v. Madigan); non-resident income taxation and out-of-state property
2006-09
2006-08
2006-07
06/27/06 Permanent Estate Tax Relief Act of 2006 (PETRA, H.R. 5638) 2006-06
05/31/06 Tax Increase Prevention and Reconciliation Act of 2005 (Pub. L. 109-222): “kiddie
tax”; conversions to Roth IRAs; expatriate income and housing exclusion; capital
gains treatment for self-created musical works
04/28/06 The AMT and stock options: capital loss carryback prohibitions apply to AMT as well
(Merlo); attempted assignment of income fails (McManus); assignment of income:
non-qualified stock options and charitable remainder trusts
2006-05
2006-04
03/29/06 4 th Circuit upholds IRS win in Chawla, but “insurable interest” issue still dangles 2006-03
02/22/06 Charitable Remainder Trust Safe-Harbor (Notice 2006-15); more on prepaid tuition;
debts, forgiveness and taxes
2006-02
Tax Topics – Table of Contents – 2013 – 6
01/27/06 Prepaid tuition (PLR 200602002); gift and estate tax reminder; “Personal Revival
Trusts” for cryonauts
2006-01
2005
12/27/05 Tax Reform Panel Recommendations; Ron Wyden’s “Fair, Flat Tax Act of 2005” 2005-12
11/18/05 Hurricane Katrina Provisions; 2006 inflation-adjusted numbers; sale of remaining
lottery payments is not a sale of a “capital asset” (Prebola)
2005-11
10/18/05 Saving for College – round-up of options 2005-10
09/30/05 Ittleson – New York taxes sale of non-resident’s artwork 2005-09
09/08/05 Estate tax thoughts; GST consequences of taxable trust renunciation (PLR
200532024); note about the “rule against perpetuities”
2005-08
07/29/05 Strangi – 5 th Circuit upholds IRS win in Texas FLP case 2005-07
06/30/05 Circular 230 2005-06
05/27/05 Estate planning glossary; Washington state’s new estate tax 2005-05
04/20/05 New Jersey loses on decoupling case (Oberhand); retroactive tax changes
(Nationsbank); charitable remainder trust “safe harbor” rules and the right of election
(Rev. Proc. 2005-24)
03/28/05 Insurable interests and trusts: Chawla; “frivolous arguments to avoid when paying
taxes” (Notice 2005-30)
2005-04
2005-03
02/18/05 Washington State decoupling struck down: Hemphill 2005-02
01/28/05 Social security, the estate tax and tax reform; several cases: Banks (contingent
attorney’s fees); Harkins (“corporation sole”); Davis (marital deduction)
2005-01
2004
12/28/04 The Barnes Foundation 2004-15
11/24/04 2005 inflation-adjusted numbers; how a low 7520 rate affects planning techniques 2004-14
11/05/04 Tax reform: flat tax and consumption tax; American Jobs Creation Act deductions for
sales tax and attorneys’ fees; New York tax law change: non-resident’s sale of co-op
now taxable
10/08/04 The Working Families Tax Relief Act of 2004 (H.R. 1308): extension through 2010 of
10% and 15% brackets; that “ridiculously complex” tax code; a word on PORC;
reminder about low 7520 rates
09/10/04 Turner v. Commissioner (formerly Thompson): 3d Circuit affirms IRS Tax Court win
against FLP (family limited partnership); Turner contrasted with Kimbell
2004-13
2004-12
2004-11
Tax Topics – Table of Contents – 2013 – 7
08/03/04 Tax Court says stock transfers to FLP are indirect gifts (Senda); co-op’s real estate
taxes not deductible against AMT (Ostrow and Guterman)
07/14/04 IRS addresses grantor trust rules and implications of tax reimbursement clauses
(Rev. Rul. 2004-64); LUST tax
06/25/04 H.R. 4520, the export bill; proposals for state and local sales tax deduction and
deferred compensation; House bills; temporary Connecticut decoupling; 7520 rate
chart
05/28/04 Kimbell v. U.S. – 5 th Circuit hands taxpayer a victory in FLP case; how the applicable
federal rates are determined
04/28/04 Export bill: economic substance doctrine, expanded “kiddie tax”; no dice on offsetting
gambling losses (TAM 200417004); QSLOB election
04/02/04 President Bush’s 2005 budget takes aim at 529 plan “loopholes”; deductibility of
attorneys’ fees – Supreme Court grants cert on Banaitis and Banks
03/18/04 Impact of 2001 and 2003 tax law changes and interplay with AMT; reminder about low
7520 rates
02/27/04 More thoughts on “decoupling”: New York, New Jersey and Connecticut – the power
of lifetime gifts; pro-rating the tax on a New York trust that changes situs
02/03/04 Tax clause nightmare: Lurie v. Commissioner, or the pain of charging taxes to a nontaxable
share; interrelated computations
01/14/04 New York fiduciary income tax and trust situs: Estate of William Rockefeller and
Matter of Harriet Bush; codification of Mercantile
2004-10
2004-09
2004-08
2004-07
2004-06
2004-05
2004-04
2004-03
2004-02
2004-01
2003
12/19/03 More changes on New York’s 529 Plan; intra-family loans: term and demand loans,
and forgiving them; note on William Roth and John Breaux
11/26/03 Inflation-adjusted numbers for 2004; charitable remainder trusts, “ordering rules”
and qualified dividends (REG-110896-98)
11/10/03 Connecticut “decouples” for a bit; New York and New Jersey “decoupling” –
disclaimers and contingent QTIPs; changes to New York’s 529 Plan
10/24/03 IRS acquiesces in Walton GRAT decision (Notice 2003-72); Social Security and “full
retirement age”
2003-21
2003-20
2003-19
2003-18
10/10/03 The Independent 529 Plan 2003-17
09/26/03 IRS guidance on reporting requirements for substitute dividends (Notice 2003-67);
the “Wall Street Rule”; tax reward money taxable (Roco)
2003-16
09/05/03 The fall legislative agenda; saving for a child’s college education 2003-15
Tax Topics – Table of Contents – 2013 – 8
08/06/03 Strangi III – the Tax Court thumps taxpayer in Texas FLP case 2003-14
07/23/03 7 th Circuit upholds IRS win in Hackl: no annual exclusion for gifts of LLC interests 2003-13
07/01/03 New York’s “tax traps” regarding the estate tax, GST and non-residents 2003-12
06/16/03 More on JGTRRA, qualified dividends and the new tax rates 2003-11
06/06/03 JGTRRA: lower rates, qualified dividends, increased child tax credit; marriage penalty
relief; increased AMT exemption; chart with phase-outs of the AMT exemption
amounts
05/16/03 Jobs and growth bill; trust’s investment fees subject to 2% floor (Scott); tax
apportionment (PNC Bank v. Roy); Michigan and the TPT credit (Lacks v. Michigan
Department of Treasury)
2003-10
2003-09
05/02/03 Jobs and growth bill; flat tax proposals; tax apportionment (Kuralt) 2003-08
04/11/03 Budget update; estate tax pitfalls for non-resident aliens (Fung); “indirect skips” and
the GST; QTIP election boo-boo (PLR 200314012); early CRUT termination and
capital gain (PLR 200314021)
03/28/03 Budget news; contingent attorneys’ fees (Raymond) – and how AMT interacts with
them
03/13/03 Budget and legislative update; marital deduction mess-up (Davis); limited education
no defense against estate tax deficiency (Koester)
02/28/03 Taxpayer’s SCIN works (Estate of Dulio Costanza); SCIN contrasted with private
annuity; IRS loses on “joint-spousal GRATs” (Cook)
02/14/03 Details on Fiscal Year 2004 Budget, including various proposed savings accounts
(lifetime, retirement and employer-sponsored); impact on 529 plans; a closer look at
arguments in favor of tax-free dividend proposal
01/31/03 State of the Union address and tax-free dividend proposal; CBO’s deficit numbers;
Sen. Daschle on the Democratic plan; is all retirement plan income “effectively” taxfree?
(KD 3761); “decoupling” in Nebraska and Kansas
01/16/03 President Bush’s job creation plan and tax proposals, including tax-free dividends;
Sen. Feinstein on freezing the top rate; JCT lists expiring provisions;House rules to
require macroeconomic analyses; dynamic scoring
2002
12/19/02 New faces: John Snow and Steven Friedman; adjustment clause too much like
Procter – Mom can’t take back gift (TAM 200245053); non-immigrant visa doesn’t
preclude domicile (Estate of Jack); payments to Holocaust survivors permanently
exempted from income tax
11/27/02 Our “abominable” tax code and how it got that way; Lindy Paull’s departure; how
7520 rates affect planning techniques – why GRATs work better with lower rates and
QPRTs don’t
2003-07
2003-06
2003-05
2003-04
2003-03
2003-02
2003-01
2002-22
2002-21
Tax Topics – Table of Contents – 2013 – 9
11/19/02 Aftermath of the mid-term elections and the AMT; estate tax issues; inflation-adjusted
numbers for 2003
10/25/02 Run-down on proposed legislation: the CARE and NESTEG bills; next year’s FICA;
low 7520 rates and planning: QPRTs, CLATs, CRATs, GRATs and charitable gift
annuities
09/20/02 Possible permanency of 2001 Tax Act and its education provisions;“decoupling”:
D.C., Massachusetts, New Jersey and New York
2002-20
2002-19
2002-18
09/04/02 Treasury ends “abusive” split-dollar scheme (Notice 2002-59) 2002-17
08/29/02 CBO’s budget numbers and stimulus proposals; IRA discussion correction – comment
from Cathy Vohs of the IRS
2002-16
08/01/02 CARE Act progresses – proposed gifts to charity from IRAs 2002-15
07/23/02 Corrections on IRA discussion; single life distribution table 2002-14
07/18/02 Corrected discussion on the final minimum distribution regs 2002-13
07/02/02 The debt limit increase; IRS retreats from imposing FICA or FUTA taxes on ISOs
(Notice 2002-47)
06/21/02 Attempts to make 2001 Tax Act permanent; efforts at estate tax reform; law-school
expenses not deductible (Galligan); ignorance of the law is no excuse – “innocent
spouse” relief denied (Mitchell)
2002-12
2002-11
05/24/02 The “sunset” provision of the 2001 Tax Act; new IRA distribution tables 2002-10
04/18/02 Thoughts on 529 Plans; IRS issues final rules on IRA distributions; “decoupling”:
Maryland, Nebraska and New York
04/09/02 Tax Court denies annual exclusion for gifts of LLC interests (Hackl); Florida says
goodbye to estate tax revenues
03/20/02 Senate Finance Committee hearing on tax shelters; Joint Committee on Taxation
report on shelters and judicial doctrines used against them
03/15/02 Stimulus bill passes; bill to freeze some of 2001 Tax Act; CBO and OMB revenue
projections; Concord Coalition suggestions about fiscal year 2003 budget; GRAT
includibility under IRC Sec. 2039 (TAM 200210009); Vermont “decoupling”; the GST
and “indirect” skips – the opt-out
02/28/02 Tax shelter amnesty (Announcement 2002-2); whither the corporate income tax?; IRS
permits early CRUT termination (PLR 200208039) and tax treatment of early
termination (PLR 200127023); IRS information on Victims’ Relief Bill (Publication
3920); New York City’s cigarette tax
02/22/02 President Bush’s fiscal year 2003 budget; Senate vote on estate tax repeal; the
shrinking surplus; increase in debt ceiling; taxability of frequent flyer miles
(Announcement 2002-18); cigarette taxes
2002-09
2002-08
2002-07
2002-06
2002-05
2002-04
Tax Topics – Table of Contents – 2013 – 10
01/31/02 Victims’ Relief bill signed – planning points; bill to reinstate marital deduction for noncitizen
spouses (H.R. 3575); the state death tax credit and “decoupling”: Minnesota,
Rhode Island and Wisconsin
2002-03
01/25/02 IRS Notice on split-dollar life insurance (Notice 2002-8) 2002-02
01/11/02 Tom Daschle speech on the economy; 2001 Report of the National Taxpayer
Advocate
2002-01
2001
12/21/01 The stimulus package; the Victims of Terrorism Relief Act; inflation-adjusted numbers
for 2002
11/30/01 More on Victims of Terrorism bill (history of prior such bills); applicability of FICA and
FUTA taxes to ISOs (incentive stock options): proposed regulations (REG-142686-01)
and Notices 2001-72 and 2001-73; the AMT and ISOs
11/26/01 Stimulus package stalls; Victims’ Relief bill progresses; 18% capital gains tax rate and
gain on principal residence exclusion (Revenue Ruling 2001-57)
10/31/01 More thoughts on the Victims of Terrorism relief bill; FICA increase; France and the
VAT
2001-25
2001-24
2001-23
2001-22
10/24/01 Stimulus plans; budget shortfalls in California, Florida, New York and North Carolina 2001-21
09/28/01 9/11 aftermath: Victims of Terrorism Relief Act 2001-20
09/04/01 More on “timing” and the new estate tax rates; the phase-out of the state death tax
credit
2001-19
08/07/01 AMT ISO relief?; “timing” and the new estate tax rates; the tax rebates 2001-18
08/02/01 Possible repeal of the “sunset” provision and the estate tax; GST “indirect” skips and
deemed allocations
2001-17
07/25/01 GST changes under 2001 Tax Act 2001-16
07/10/01 Two unfavorable IRA rulings: sons can’t be default “designated beneficiaries”
(PLR 2001260410) and daughter can’t name herself as Mom’s designated beneficiary
after Mom’s death (PLR 200126036); new IRA rules wouldn’t necessarily have made
a difference
2001-15
06/29/01 Some of the numbers behind the 2001 Tax Act 2001-14
06/04/01 Rundown on EGTRRA (the 2001 Tax Act) 2001-13
05/22/01 Gifts to non-grantor trusts under the “Relief” bill; Neal tries to shut down swap funds
(H.R. 1785)
2001-12
05/18/01 Rundown on the “Relief” bill; the “Byrd rule” 2001-11
Tax Topics – Table of Contents – 2013 – 11
04/20/01 Costs of the “Death Tax Elimination” bill; the Joint Committee on Taxation and
revenue estimates; estate tax reform bills; Rangel bill would make state and local
taxes deductible against AMT
2001-10
04/13/01 The costs of estate tax repeal 2001-09
04/11/01 President Bush’s tax proposals, H.R. 8, “The Death Tax Elimination Act of 2000,”
carryover basis and “dynamic” versus “static” scoring
2001-08
03/23/01 Competing stimulus bills and possible estate tax relief 2001-07
03/07/01 Stimulus bill in the making; IRA hardship exemption fails (Gallagher); tax fraud
conviction and sentencing of Dorothy and George Henderson; office space for the
Clinton Foundation
02/05/01 Projected budget surpluses; President Bush’s tax plan; possible estate and gift tax
repeal
2001-06
2001-05
01/30/01 Clarification on new proposed IRA regs 2001-04
01/24/01 Appendix with new IRA distribution period 2001-03
01/22/01 Senate Finance Committee takes shape; new proposed regs on IRA distributions
(REG-130477-00 and REG-130481-00)
01/10/01 Tax-writing committees take shape; possible tax legislation; IRS loses Walton GRAT
case; how tax credits lard up the tax code; joint spousal revocable trust wins and
loses
2001-02
2001-01
2000
12/20/00 The $1.3 trillion tax cut; inflation-adjusted numbers for 2001 2000-19
11/29/00 Thoughts on the new faces in Washington; candidates for Chairman of the House
Ways and Means Committee
11/22/00 The uncertain outcome of the elections; compromise bill on the foreign sales tax
regime; standard mileage rates
2000-18
2000-17
11/17/00 Election outcome unknown, but what the tax-writing committees may look like 2000-16
10/30/00 House passes tax bill, Clinton promises veto; NY streamlines tuition savings plan;
FICA increases and Social Security funding
10/18/00 Details on 18% capital gains tax rate; deduction and credit for college tuition;
conviction of Dorothy and George Henderson for tax fraud
2000-15
2000-14
10/02/00 H.R. 1102, the “Retirement Security and Savings Act of 2000”; estate tax update 2000-13
Tax Topics – Table of Contents – 2013 – 12
09/15/00 Override on “marriage penalty” veto fails; Republican edge in House
narrows;“surviving spouse” in same-sex relationship loses 50% co-ownership
argument (Estate of Horstmeier); credit for tax on prior transfers doesn’t fly (Estates of
Harrison); Gov. Jesse Ventura on Minnesota public school education
09/08/00 Override on estate repeal veto fails; final GRAT regulations issued (T.D. 8899, 26
CFR Part 25); settlement fees and tax apportionment (Estate of Esther Brabson);
dependency exemption for kidnapped child (ILM 200034029)
2000-12
2000-11
08/07/00 Strategies for passing tax reform; New Hampshire upholds inheritance tax 2000-10
07/14/00 Thoughts on possible estate tax repeal; New Hampshire House overrides inheritance
tax repeal veto; the problem of joint-ownership (PLR 200034029); draft legislation to
permit fair market value deduction for charitable contributions by artists and authors
(S. 2781)
2000-09
06/29/00 Projected surpluses; estate tax repeal movement 2000-08
06/09/00 New Hampshire governor vetoes inheritance tax repeal; IRS ruling on a “5 & 5”
power: ever-increasing ownership of the trust (PLR 200022035); IRS wins two cases:
gifts to a corporation don’t qualify for annual exclusion (Stinson); “economic benefit”
doctrine doesn’t accelerate taxability of lottery winnings (Thomas)
05/19/00 H.R. 8 and estate tax repeal; embezzled money is taxable income (Amini); no
“married filing jointly” available for taxpayer in same-sex relationship (Mueller)
05/15/00 Estate tax valuation of a disputed claim: Estate of Algerine Smith. Commissioner – 5 th
Circuit reverse Tax Court
04/13/00 IRS goes after “ghoulish” charitable lead trusts (REG-100291-00; new tax shelter
listings apply to individuals as well as corporations; IRS permits disclaimer to change
IRA beneficiaries (PLR 200013041); community property IRA distribution to exspouse
taxable to IRA owner (Bunney); charitable bequest of non-qualified stock
options taxable to charity, not estate (PLR 20012076)
03/24/00 Donees subject to transferee liability (Armstrong); converting NIM-CRUTs to CRUTs
(Notice 99-31); discharge of GRAT liability (TAMs 200010010 and 200011005)
02/28/00 Corporate tax refunds are up; taxpayer wins Texas partnership case (Elsie Church v.
United States)
0/11/00 President Clinton’s final budget (fiscal year 2001); attempted casualty loss for
property next to O.J. Simpson’s estate (Chamales)
2000-07
2000-06
2000-05
2000-04
2000-03
2000-02
2000-01
Tax Topics – Table of Contents – 2013 – 13
Blanche Lark Christerson is a managing director at Deutsche Asset & Wealth Management in New York
City, and can be reached at blanche.christerson@db.com.
The opinions and analyses expressed herein are those of the author and do not necessarily reflect those of Deutsche Bank AG or any
affiliate thereof (collectively, the “Bank”). Any suggestions contained herein are general, and do not take into account an individual’s
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Tax Topics – Table of Contents – 2013 – 14