AICPA Comments on Proposed Regs on Affect of Post-Death Events on Estate Valuation

On August 8, 2007, the AICPA asked for changes to the proposed regulations under section 2053 on the affect of post-death events on valuing contingent liabilities of the estate. Learn More>>

AICPA Requests Guidance on Allocating Indirect Deductions for CRTs

June 26, 2007. This letter requests IRS provided guidance on the allocation of indirect deductions for CRTs. Learn More>>

AICPA Requests Guidance on Split Gifts When Donee Spouse Has an Interest

June 26, 2007. This letter requests IRS guidance on the ability to split gifts under section 2513 when the donee spouse has an interest in the trust but all the transfers made to the trust during the year may be withdrawn by trust beneficiaries. Learn More>>

AICPA Asks for Simplified Extension Procedure to Elect Out of Automatic GST Allocation

June 26, 2007. This letter requests IRS provide a simplified procedure to obtain extension of time to elect out of the automatic allocation of GST exemption to indirect skips, similar to Rev. Proc. 2004-46. Learn More>>

AICPA Asks for Guidance on GST Allocation at the End of the ETIP

June 26, 2007. This letter requests IRS guidance on the allocation of GST exemption to a trust at the end of the estate tax inclusion period (ETIP) or electing out of the automatic allocation rules at the end of the ETIP. Learn More>>

AICPA Comments on Foreign Trust Reporting Forms

On January 31, 2007, the AICPA submitted comments to the IRS on various foreign trust reporting issues. The comments address issues related to foreign trusts, foreign gifts, Canadian registered education savings plans, and nonresident aliens and Notice 97-34 and various foreign trust regulations. The comments also include 15 specific recommendations related to revisions, filing changes, and extensions for Forms 8891, 3520, and 3520-A, and 1040NR, and creating a Form 1041NR for foreign grantor trusts with U.S. owners. Learn More>>

Spousal Rights Election and CRTs Under Section 664 June 8, 2005. The AICPA expresses concerns about Rev. Proc 2005–24, saying it creates many traps for the unwary and has the potential to disqualify every inter vivos charitable remainder trust, created on or after June 28, 2005. Learn More>>

Alert on IRS Requiring Spousal Waivers to Avoid CRT Disqualification This alert discusses the IRS recently issued controversial Rev. Proc. 2005-24, which requires spousal waivers to avoid disqualification of certain charitable remainder trusts (CRTs), whether they are charitable remainder annuity trusts or unitrusts. It briefly covers some background on the new rules and urges practitioners to read the guidance. Learn More>>

IRS Revenue Procedures on Charitable Remainder Unitrust (CRUT) Sample Declarations IRS has provided an annotated sample declaration of trust and alternate provisions that satisfy the requirements of section 664 for inter vivos charitable remainder unitrusts that provide unitrust payments for one measured life followed by a charitable distribution of trust assets. Learn More>>

AICPA Asks IRS to Clarify Qualified Severance Regs. for GST Trusts February 9, 2005. The AICPA recommends clarifying the proposed regs on qualified severance of a generation-skipping transfer trust, suggesting that the qualified severance rules should apply only if the single trust is divided on a fractional basis. Learn More>>

AICPA Recommends Clarifications to Proposed GST Predeceased Parent Exception Regs. December 9, 2004. This letter contains the AICPA comments regarding proposed regulations on the predeceased parent rule. That rule provides an exception to the generation-skipping transfer tax generation assignment rules that assigns a higher generation to transferees when the parent of the transferee is deceased. Learn More>>

AICPA Recommends Clarifying Regs on "Electing Out" of GST Deemed Allocations November 10, 2004. This letter contains the AICPA comments regarding proposed regulations on electing out of generating-skipping transfer tax deemed allocations under section 2632(c). Learn More>>

AICPA Comments on Revised Gift Tax Form 709 and Its Instructions May 18, 2004. This letter contains AICPA comments on Form 709 and instructions. Learn More>>

AICPA Offers Comments on GST Safe Harbor Regs. July 30, 2003. This letter contains Safe Harbor Suggestions under Proposed Section 2642(g) Regulations. Learn More>>

AICPA Comments on Form 3520-A, "Annual Information Return of Foreign Trust with a U.S. Owner" June 17, 2003. This statement contains the AICPA comment letter on new reporting requirements for Canadian RRSPs and RRIFs. Learn More>>

IRS Responds to AICPA Concerns for Filing the Form 3520 for Canadian RRSPs This article contains the AICPA Alert to Members regarding the August 1, 2003, IRS Notice 2003-57 on Canadian RRSPs and Forms 3520 and 3520-A Reporting Requirements. Learn More>>

AICPA Comments on the Foreign Trust Reporting Rules for Forms 3520 and 3520-A June 17, 2003. These comments concern Form 3520 and Form 3520-A and reporting requirements for Canadian RRSPs. Learn More>>

Alert on Expat Transitional Rules for New Form 8854 This alert covers expatriate transitional rules for Form 8854, Initial and Annual Expatriation Information Statement. Learn More>>

Guide to Section 643 Regs Defining Trust Income This guide analyzes the revised regulations defining trust accounting income for tax years ending after January 2, 2004, and examines how they affect the computation of fiduciary accounting income and distributable net income. Learn More>>