Estate and Gift Taxes

Important developments during the year submitted by the Committee on Estate and Gift Taxes are discussed. In TD 9077, the Treasury set forth final regulations under sections 2519 and 2207A concerning the gift tax consequences of a deemed gift of qualified terminable interest property. In TD 9102, Th...

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Bibliographic Details
Published in:The Tax lawyer 2004-07, Vol.57 (4), p.1061-1071
Main Authors: Siegler, Douglas L., Berek, David A.
Format: Article
Language:English
Subjects:
Annuity payments
Collaboration
Estate taxes
Federal court decisions
Gift taxes
Gross estates
IMPORTANT DEVELOPMENTS DURING THE YEAR
Income taxes
Property taxes
Qualified Terminable Interest Property
Revenue rulings
Spouses
State court decisions
Tax court decisions
Tax courts
Tax payments
Tax regulations
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Summary:Important developments during the year submitted by the Committee on Estate and Gift Taxes are discussed. In TD 9077, the Treasury set forth final regulations under sections 2519 and 2207A concerning the gift tax consequences of a deemed gift of qualified terminable interest property. In TD 9102, The Treasury set forth final regulations that revised the definition of income under section 643(b) and clarified when capital gains are included in distributable net income under section 643(a)(3). In Brown v. United States (2003), the Ninth Circuit affirmed a district court decision requiring that a decedent's gross estate be increased by the amount of gift taxes paid on a gift made within 3 years of death. In Schott v. Commissioner (2003), the Ninth Circuit reversed the Tax Court and held that a 2-life annuity with a limit of 15 years was a "qualified interest" under section 2702.
ISSN:0040-005X
2329-6089