Without much doubt, the most complex, convoluted and confusing provision in the family-owned business exclusion (FOBE) is the pre-death requirement that the adjusted value of qualified family-owned business interests (plus pre-death gifts of family-owned business interests within the family) must exceed 50 percent of the decedent’s adjusted gross estate (with various modifications). The calculation involves a fraction with both the numerator and the denominator posing formidable problems of interpretation
The battle over the portion of value of property owned in joint tenancy (or tenancy by the entirety)...
Leaving property at death to the surviving spouse for life (a legal life estate or a life estate in ...
Over the last 30 years, substantial changes have emerged over the taxation of co-owned assets (other...
The family-owned business exclusion, enacted as part of the Taxpayer Relief Act of 1997 contained nu...
One of the centerpieces of the Taxpayer Relief Act of 1997 was the family-owned business exclusion, ...
Funding the marital and non-marital shares in a farm or ranch estate is always an important decision...
A dispute between the Internal Revenue Service and an estate in 1988 that first raised the question ...
As has been reported since the 1997 enactment of the family-owned business deduction and the substan...
The confusion over the pre-death and post-death material participation requirements for special use ...
Items of income in respect of decedent require careful planning attention after death. As property t...
The inadequacies of the lien provision in the family-owned business deduction statute are prompting ...
The dramatic increase in recent years of the level of the applicable exclusion for federal estate ta...
In 1986, Congress enacted legislation allowing solvent farm debtors to avoid income from the dischar...
A decision by the Fifth Circuit Court of Appeal, on July 18, 2001, affirmed a decision of the United...
The rule has been well settled since publication of the qualified use regulations in 1980 that lan...
The battle over the portion of value of property owned in joint tenancy (or tenancy by the entirety)...
Leaving property at death to the surviving spouse for life (a legal life estate or a life estate in ...
Over the last 30 years, substantial changes have emerged over the taxation of co-owned assets (other...
The family-owned business exclusion, enacted as part of the Taxpayer Relief Act of 1997 contained nu...
One of the centerpieces of the Taxpayer Relief Act of 1997 was the family-owned business exclusion, ...
Funding the marital and non-marital shares in a farm or ranch estate is always an important decision...
A dispute between the Internal Revenue Service and an estate in 1988 that first raised the question ...
As has been reported since the 1997 enactment of the family-owned business deduction and the substan...
The confusion over the pre-death and post-death material participation requirements for special use ...
Items of income in respect of decedent require careful planning attention after death. As property t...
The inadequacies of the lien provision in the family-owned business deduction statute are prompting ...
The dramatic increase in recent years of the level of the applicable exclusion for federal estate ta...
In 1986, Congress enacted legislation allowing solvent farm debtors to avoid income from the dischar...
A decision by the Fifth Circuit Court of Appeal, on July 18, 2001, affirmed a decision of the United...
The rule has been well settled since publication of the qualified use regulations in 1980 that lan...
The battle over the portion of value of property owned in joint tenancy (or tenancy by the entirety)...
Leaving property at death to the surviving spouse for life (a legal life estate or a life estate in ...
Over the last 30 years, substantial changes have emerged over the taxation of co-owned assets (other...