Ray D. Madoff: The Case for Giving Away Money Now Rather Than Through Perpetual Private Foundations (Wall St. J. June 16, 2019).

Ray D. Madoff, Boston College, has written an opinion editorial in the Wall Street Journal arguing that it is more effective for philanthropists to give away money now than through perpetual private foundations. His op ed piece begins as follows: When it came to investing, no one was smarter than Lewis B. Cullman, who died … Continue reading Ray D. Madoff: The Case for Giving Away Money Now Rather Than Through Perpetual Private Foundations (Wall St. J. June 16, 2019).

Clausing: Fixing the Five Flaws of the Tax Cuts and Jobs Act (May 28, 2019)

Kimberly A. Clausing, Reed College Dept. of Economics has made available for download her article, Fixing the Five Flaws of the Tax Cuts and Jobs Act (May 28, 2019). The Abstract is as follows: The tax legislation commonly referred to as the Tax Cuts and Jobs Act (Public Law 115-97) came into effect in 2018. … Continue reading Clausing: Fixing the Five Flaws of the Tax Cuts and Jobs Act (May 28, 2019)

PLRs 201925005-201925010: Trusts with Power of Appointment Committee Not Grantor Trust

In PLRs 201925005-201925010 the IRS made the following rulings: The trust was not a grantor trust as to either the grantor or any members of the Power of Appointment Committee.Contributions of assets to the trust by the Grantor were not completed gifts. Distributions to beneficiaries would not be completed gifts by Power of Appointment Committee … Continue reading PLRs 201925005-201925010: Trusts with Power of Appointment Committee Not Grantor Trust

Alarie, Turning Standards into Rules Part 1: Using Machine Learning to Predict Tax Outcomes.

Benjamin Alarie, University of Toronto, has made available for download his article, Turning Standards into Rules Part 1: Using Machine Learning to Predict Tax Outcomes, published in the Bloomberg BNA Daily Tax Report. The Abstract is as follows: Technological advancements in the last 10 years have made it possible to explore the application of data … Continue reading Alarie, Turning Standards into Rules Part 1: Using Machine Learning to Predict Tax Outcomes.

Commentary Omnibus.2019.0623: Taxing the Rich, Estate Planning With Frequent Flier Miles, Perpetual Charitable Trusts and Foundations, etc!

David Leonhardt, Yes, Taxing The Rich Is Possible, NY Times (June 5, 2019).Paul Caron, Tax Prof Blog: Tax Policy in the Trump Administration (June 14, 2019).Paul Caron, Tax Prof Blog: Univ. of Illinois Symposium on Basic Income (2019).WSJ: Charitable Gifts Slip in First Year Under New GOP Tax Law (June 18, 2019).Adler: Insight on Estate … Continue reading Commentary Omnibus.2019.0623: Taxing the Rich, Estate Planning With Frequent Flier Miles, Perpetual Charitable Trusts and Foundations, etc!

Elizabeth Siefker, Character: The Unacknowledged Element in Shifting the Burden of Proof in a Will Contest

Elizabeth Siefker has published her article, Character: The Unacknowledged Element in Shifting the Burden of Proof in a Will Contest, 96 U. Det. Mercy L. Rev 457 (2018-2019). Ms. Siefker's article focuses on Michigan law and it's paradigm where the character of the parties to a will contest is an unacknowledged elements in the shifting … Continue reading Elizabeth Siefker, Character: The Unacknowledged Element in Shifting the Burden of Proof in a Will Contest

Supreme Court Opinion: North Carolina Dept. Rev. V. Kaestner 1992 Family Trust – The presence of in-state beneficiaries alone does not empower a State to tax trust income that has not been distributed to the beneficiaries where the beneficiaries have no right to demand that income and are uncertain to receive it (June 21, 2019)

The Supreme Court has issued its opinion in North Carolina Dept. Rev. V. Kaestner 1992 Family Trust, 588 U.S. ___ (2019). The Supreme Court held that "The presence of in-state beneficiaries alone does not empower a State to tax trust income that has not been distributed to the beneficiaries where the beneficiaries have no right … Continue reading Supreme Court Opinion: North Carolina Dept. Rev. V. Kaestner 1992 Family Trust – The presence of in-state beneficiaries alone does not empower a State to tax trust income that has not been distributed to the beneficiaries where the beneficiaries have no right to demand that income and are uncertain to receive it (June 21, 2019)