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    AICPA Comments to IRS on Annuities - March 6, 2007

    Comment Letter This is a 3/6/07 AICPA letter to the IRS regarding annuity proposed regs. The AICPA believes that the proposed regulations are overly broad in nature and attempt to curb perceived abuses that could be managed in a much less intrusive...
    Published on March 14, 2012

    Article on IRS Approving Income Deferral CRT Funded with Tax Deferred Annuities - March 17, 1999

    Article This is a 3/17/99 article from the Planned Giving Design Center (PGDC), providing a review of the IRS Income Deferral in Charitable Remainder Trusts (CRT) Ruling of 1999. The article provides a background of income deferral in CRTs and what the Service advised in their Technical Advice Memorandum.
    Published on March 05, 2012

    Comprehensive List of Advocacy Issues for Trust, Estate and Gift Tax

    Article This section includes information on legislative, regulatory, and administrative advocacy related to estate, gift, and trust taxation.
    Published on March 31, 2014

    SOGRAT Patent - May 20, 2003

    Federal Law This is the 5/20/003 SOGRAT (stock option grantor retained annuity) patent
    Published on March 05, 2012

    Interesting Specific Tax Strategy Patents and Patent Applications

    Overview This page contains specific interesting tax strategy patents.
    Published on September 19, 2014

    Information on Lawsuits on Specific Tax Strategy Patents

    Overview This page contains information on lawsuits concerning the SOGRAT and Fort Properties Section 1031 likekind exchange deedshare patents, as well as other information on specific tax strategy patents.
    Published on September 19, 2014

    PLR on CRTs Regarding Lang CRT Patent - Sept. 14, 1999

    Guidance ...the 9/14/99 PLR from the Service, ruling on an issue regarding the Lang CRT patent. It covers a CRUT with net income provision and owns a variable annuity contract qualifies under section 664. The trust includes any annuity contract income in its ordinary income for the year under section 72(u
    Published on March 05, 2012

    IRS TAM on Income Deferral CRTs - for the Lang CRT Patent - July 3, 1998

    Guidance The 7/3/98 IRS Technical Advice Memorandum approving an arrangement where the trustee of a charitable remainder unitrust invested trust assets in two tax deferred annuity contracts for the purpose of controlling the timing & amount of distributions
    Published on March 05, 2012

    GRAT Provision Passed House of Representatives

    Article ...as part of H.R. 4849, the Small Business and Infrastructure Jobs Tax Act of 2010, a revenue raiser requiring a minimum of 10 years for a Grantor Retained Annuity Trust (GRAT
    Published on September 11, 2012

    AICPA Letter to IRS on Section 664 Guidance on Effect of UBTI on CRTs - June 12, 2008

    Comment Letter ...unrelated business taxable income (UBTI) does not remain as such if it is distributed by a charitable remainder trust (CRT) to a charitable organization as part of the annual annuity or unitrust payment
    Published on March 14, 2012

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