How Trust-Like Is Russia's Fiduciary Management? Answers from Louisiana by Markus G. Puder (Dec. 6, 2019)

Markus Puder has made his paper, How Trust-Like Is Russia's Fiduciary Management? Answers from Louisiana, available for download. This article was published as a research paper at Loyola University New Orleans College of Law. The abstract of this article, available on SSRN, reads as follows: This article introduces Russia's legal concept of “fiduciary management” - … Continue reading How Trust-Like Is Russia's Fiduciary Management? Answers from Louisiana by Markus G. Puder (Dec. 6, 2019)

National Taxpayer Advocate delivers Annual Report to Congress: focuses on Taxpayer First Act implementation, taxpayer service, and IRS funding

 Acting National Taxpayer Advocate Bridget Roberts has released her 2019 Annual Report to Congress. Key challenges highlighted in the report include implementation of the Taxpayer First Act, inadequate taxpayer service and limited funding of the agency. Roberts also released the third edition of the National Taxpayer Advocate's "Purple Book," which presents 58 legislative recommendations designed to strengthen taxpayer … Continue reading National Taxpayer Advocate delivers Annual Report to Congress: focuses on Taxpayer First Act implementation, taxpayer service, and IRS funding

Eric Penzer: Waiving a Decedent's Attorney-Client Privilege, NY T&E Litigation Blog (Jan. 8, 2020).

Eric Penzer, of Farrell Fritz, writes about how a decedent's attorney client privilege can be waived, which was recently discussed by the Supreme Court of New York, Appellate Division, Fourth Judicial Department. Mr. Penzer's article begins as follows: “The attorney client privilege, the oldest among common-law evidentiary privileges, fosters the open dialogue between lawyer and … Continue reading Eric Penzer: Waiving a Decedent's Attorney-Client Privilege, NY T&E Litigation Blog (Jan. 8, 2020).

Resolving the Status of the Bare Trust by Robert Flannigan (Jan. 5, 2020)

Robert Flannigan has made his paper, Resolving the Status of the Bare Trust, available for download. This article was published as a part of a working paper series. The abstract of this article, available on SSRN, reads as follows: A number of diverse arrangements commonly are described as “bare trusts.” Trustees are said to be … Continue reading Resolving the Status of the Bare Trust by Robert Flannigan (Jan. 5, 2020)

IRS Updated Audit Guide: Structured Settlements

The IRS has updated its Audit Techniques Guide that addresses excise tax on structured settlement factoring transactions. Audit Guides focus on developing highly trained examiners for particular market segments by presenting examination techniques, common and unique industry issues, business practices, industry terminology and other information. To see the updated Structured Settlement Audit Guide click here.

IRS: Updated Audit Techniques Guide: Real Estate Foreclosures, Short Sales and Cancellation of Debt

The IRS has updated its Audit Techniques Guide that addresses the tax consequences for real estate property that is disposed of through foreclosure, short sale, deed in lieu of foreclosure and abandonments. Audit Guides focus on developing highly trained examiners for particular market segments by presenting examination techniques, common and unique industry issues, business practices, … Continue reading IRS: Updated Audit Techniques Guide: Real Estate Foreclosures, Short Sales and Cancellation of Debt

US v. Kohls, 2020-1 U.S.T.C. ¶60,719, (Jan. 2, 2020), executor personally liable for unpaid estate tax

In US v. Kohls, 2020-1 U.S.T.C. ¶60,719, (Jan. 2, 2020), the US District Court for the Southern District of Ohio held that an executor of a decedent’s estate was personally liable for unpaid estate tax after he distributed property to himself and other beneficiaries before paying the estate tax.  The IRS notified the estate that … Continue reading US v. Kohls, 2020-1 U.S.T.C. ¶60,719, (Jan. 2, 2020), executor personally liable for unpaid estate tax