IRS gives expatriates income and gift tax relief

Article Abstract:

The IRS has issued revenue ruling 92-109 on expatriates whose citizenship is restored as regards their income and gift tax status. US citizens who perform an expatriating act and have their citizenship revoked are not liable for income or gift taxes until the year that their citizenship is reinstated. Persons who thought their citizenship had been revoked and can demonstrate their belief of this are eligible for similar consideration. The IRS is attempting to entice voluntary compliance with tax laws by removing certain penalties.

Tax exemption, Tax exemptions, Expatriation, Non-resident aliens, Nonresident aliens

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When can the surviving spouse roll over the decedent's IRA?

Article Abstract:

Making a trust or estate the beneficiary of an IRA may prevent the use of the spousal rollover provision and the inclusion of the rolled over assets as part of the basis for the marital deduction. Letter Ruling 9445029 held that a woman could not include rolled over IRA assets as part of her estate for the marital deduction because a third party, a bank, was named the owner of the IRA. Even though the spouse had power to revoke the trust, she was not the trustee proper.

Individual retirement accounts, Rollovers (Finance)

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Intrafamily transfer was included in lender's estate

Article Abstract:

The Claims Court ruled in Estate of Musgrove that a transfer between a father and his son was a gratuitous loan, and therefore includable in the descendant's estate, which was inherited by the son. The court was swayed to this decision by the fact that the father was 84 when he made the loan, and structured it so that it would not need to be repaid if he should die before the balance came due.

United States, Cases, Decedents' estates, Valuation, Loans

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