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Charitable planning with interests in pass-through entities is complicated by various pitfalls. A practitioner advising a client in this type of planning is required to master a significant number of [...]

A common estate planning technique is a transfer (by gift or sale) to an irrevocable trust. If the transfer is of a hard-to-value asset, such as an interest in a [...]

Much has been written about what to do and what not to do in establishing and administering family limited partnerships ("partnerships") to survive attacks by the Internal Revenue Service (IRS) [...]

In the September/October 2009 issue of Probate & Property, the authors ran a flyer requesting that readers visit the ABA's website to vote for the 10 tax rulings that are [...]

Last month I discussed how creditor protection under ERISA is affected when the only participant in a retirement plan is a sole stockholder (or sole proprietor) and spouse. This month [...]

We certainly live in a litigious society. The relevance of that fact has not been missed by those who practice in the medical profession, especially when it comes to protecting [...]

The article discusses the formula transfer clause and the Wandry vs. Commissioner case, the first case upholding a formula transfer clause. The authors note that transfer clauses offer a solution to the desire of a taxpayer to make a transfer of a specific dollar amount of a hard-to-value asset without risking a revaluation of a transferred property resulting in gift tax. They state that the Wandry case is a Tax Court memorandum opinion attributed only to its writer, Judge Harry A. Haines.

The article discusses ways to generate liquidity to pay estate administration expenses and inheritance taxes after the taxpayer's death and presents several court cases dealing with post-death payments from partnerships. It informs about the applicability of the section 2036(a) of the Internal Revenue Code (IRC) on several cases including Estate of Strangi v. Commissioner. It mentions that this code is not applicable in Estate of Black v. Commissioner, and Keller v. United States.