Forbes

Why The IRS Will Continue To Challenge Section 643(b) Trusts

The last few years have seen the proliferation of so-called section 643(b) trusts. Although there are various iterations of these trust arrangements, a common purpose seems to permeate each of them: ...
JD Supra

Can the IRS Assert IRC Section 6676’s Erroneous Refund Penalty on Protective Refund Claims?

We once again want to bring to your attention the Internal Revenue Service’s (IRS) new favorite penalty provision: Internal Revenue Code (IRC) Section 6676. We have reported on this provision several ...
Wealth Management

Bridging Section409A And Gift Tax Valuations

Clients may be inclined to use a Section 409A valuation for gift tax purposes. After all, both valuations aim to determine ...
JD Supra

IRS Creates Standardized Form for Section 83(b) Elections

Earlier this month, the Internal Revenue Service (“IRS”) released Form 15620, which is an approved IRS form for making Internal Revenue Code (“Code”) Section 83(b) elections. By way of background, ...