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Writing on behalf of Deloitte Tax LLP, Laura Peebles has suggested that proposed regulations that would require attaching a complete appraisal with Form 8283 in any year in which an income tax charitable contribution deduction is carried over be removed and that including a copy of prior years' Forms 8283 would be sufficient. More
Service Issues Trick or Treat Notice Regarding CRT Transaction
The IRS on Halloween issued Notice 2008-99 in which it announced its interest in a type of transaction involving the sale of interests in a charitable remainder trust that might result in inappropriate tax avoidance by the trust's grantor. The notice requires any persons entering into and material advisers who make a tax statement regarding such transactions, as well as charitable remaindermen that participate to disclose the transaction to the IRS. In addition, the Service and Treasury are requesting public comments on how the transaction might be addressed in published guidance. More
Estate Tax Charitable Deduction Denied
The United States District Court for the District of Kansas has denied an estate tax charitable deduction for a testamentary charitable remainder trust based on the fact the trust did not conform to the requirements of section 2055 and a petition to reform the trust was not filed before the 90th day after the last date (including extensions) for filing the estate tax return. More