American Tax Payer Relief Act 2012

The Estate Planner’s Guide to the “Deal”

The business attorney’s focus when advising a client selling a business is necessarily the transaction itself. Primary considerations typically include maximizing the purchase price, reducing the income and other (e.g., real estate excise) taxes resulting from the transaction, and minimizing post-transfer contingencies placed upon the seller’s receipt of the sale proceeds (e.g., earn-out provisions). Although all of these factors are … Continue reading »

img_gavelMoney_540x360

Tax Court Rules for MPBA Clients in Rejecting Aggressive IRS Estate Tax Claim

In Estate of Purdue, T.C. Memo. 2015-249, the United States Tax Court denied an IRS attempt to disregard lifetime estate planning implemented by Barbara and Robert Purdue (the “Purdues”). MPBA attorneys, primarily Alan L. Montgomery and George W. Akers, advised Mr. and Mrs. Purdue with respect to the lifetime planning, and also represented Mrs. Purdue’s estate (the “Estate”) at the Tax Court. The Estate … Continue reading »

estatetaxplanning

Proposed IRS Regulations May Limit Tax-Favorable Estate Planning Strategies

The IRS recently announced new proposed regulations which may eliminate or significantly reduce valuation discounts on transfers of family entity interests (e.g., LLCs, limited partnerships, and corporations). Although there are several uncertainties regarding the scope of these new rules, the proposed regulations, if enacted, could result in substantial increases in estate, gift, and generation-skipping transfer taxes for many taxpayers. Continue reading »

state_court_of_appeals_affirms_finality_of_order_approving_trust_accounting

Bernard Decision Confirms Intent and Purpose of TEDRA

In In Re Estate of Bernard, 182 Wn. App. 692, 332 P.3d 480 (2014), review denied 339 P.3d 634 (2014), the Washington State Court of Appeals Division 1 reversed a trial court order invalidating a trustor’s estate plan.  In upholding the validity of the testamentary documents, the appellate court’s ruling confirmed long-standing practices of Washington State estate planners relating to … Continue reading »