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 »

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 »

2014 Estate Planning and Tax Update

How have federal income tax laws changed recently? While the 2012 Tax Act did not change income tax rates for most taxpayers, those individuals with incomes over $400,000 and married couples filing jointly with incomes over $450,000 are now subject to a highest marginal rate of 39.6%, up from 35%. A 20% rate now applies to long-term capital gains and … Continue reading »