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Emma Slack-Jorgensen
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SCOTUS Addresses Constitutional Challenge to Mandatory Repatriation Tax
Federal Taxation
In Moore v. U.S. (36 F. 4th 930), the U.S. Supreme Court ruled on a constitutional challenge of IRC section 965, the…
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Estate of Fields v. Comm’r—Bad Facts Family Limited Partnership Causes Estate Tax Inclusion under IRC Section 2036(a)(1) and (2) with Accuracy-Related Penalty Imposed
Federal Taxation
Estate of Fields v. Commissioner, T.C. Memo. 2024-90 (Sept. 26, 2024) (Copeland, J.), provides a textbook example of a “bad…
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IRS to Stop Automatically Assessed 3520 Late Filing Penalty on Large Foreign Gifts
Federal Taxation
At the end of October 2024, the IRS announced that it will no longer automatically assess penalties for late reporting of…
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The Sunset of the Doubled Estate, Gift, and GST Tax Exclusion Amounts after December 31, 2025 – What High Net Worth Individuals and Family Offices Need to Know About It
Federal Taxation
In the world of high-net-worth individuals and their financial advisors, the sunset of certain provisions of the 2017 Tax…
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Charitable Planning for Individuals
Federal Taxation
Charitable contributions play a crucial role in addressing important needs within our communities, and the U.S. tax code…
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The U.S. Supreme Court Affirms the Eighth Circuit’s Decision in Favor of the Government Concerning the Estate Tax Treatment of Life Insurance Proceeds Used to Fund a Corporate Redemption Obligation
Federal Taxation
In Connelly v. U.S., 602 U.S. ___ (6/6/2024), the United States Supreme Court affirmed a decision of the Eighth Circuit Court…
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Penalties in Modern Tax Practice
Federal Taxation
“In 1955, there were approximately 14 penalty provisions in the Internal Revenue Code. There are now [in 2011] more than…
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The YA Global Tax Court Decision: Private Fund Activities Drag Non-U.S. Fund Investors Into the U.S. Tax Net
Federal Taxation
For U.S. history aficionados, November 15 is an auspicious day: It was on this day in 1777 that the Continental Congress…
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Nothing to Fear but Fear Itself: Planning in the Current Environment
Federal Taxation
As the calendar turns to 2024, taxpayers and their advisors face an uncertain future. Given a divided government for at…
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