Trusts and estates may benefit from the “unlimited” charitable income tax deduction under Sec. 642(c), which may be especially attractive to a philanthropic grantor seeking to completely eliminate ...

In our global economy, even a tariff of less than 10% can have a significant impact on the supply chains that cross national borders. Blanket tariffs of 10% and “reciprocal” tariffs of well over 25% ...

The midyear change follows an increase in gasoline prices, according to the IRS. It is the first such midyear adjustment since 2022. The final regulations target arrangements that the IRS says ...

The final regulations target arrangements that the IRS says improperly use charitable remainder annuity trusts and annuities to eliminate ordinary income and capital gain on the sale of property.

Many investment funds employ an economic arrangement in which the general partner receives a carried interest, and the management company, which often shares common ownership with the general partner, ...

The basic rule for when a partner recognizes gain as a result of a distribution is found in Sec. 731(a)(1), which applies to both current distributions (from current income and activities) and ...

Editor: Mary Van Leuven, J.D., LL.M. Mary Van Leuven, J.D., LL.M., is a director, Washington National Tax, at KPMG LLP in Washington, D.C. For additional information ...

First, ordinary income and such undistributed income of the trust for prior years; Second, capital gain (including unrecaptured Sec. 1250 gain and gain on collectibles taxed at 28%) and such ...

Distributions from a trust to a beneficiary can take many forms and can have widely varying consequences. The timing of the distribution, the type of asset distributed, the requirements under the ...

Owners often consider whether to borrow money to grow their business operations. A huge component of that decision is the deductibility of interest on the loans. Sec. 163(j) imposes a potentially ...

A mismatch in determining whether a transfer is complete under the income tax regime on the one hand and the transfer tax regime on the other creates what could be considered an estate planning ...

This annual update summarizes key changes advisers need to be aware of to ensure their clients’ estate plans remain effective and in line with their intentions. It covers developments in the estate ...