Webinar
Drawn from Steve Gorin’s 2nd quarter 2023 newsletter, our presenter will cover important recent cases on how to satisfy the adequate disclosure requirements for gift tax returns, when transactions between shareholders and corporations constitute constructive dividends, and transferee liability for estate tax that may now be imposed on beneficiaries automatically when they receive a bequest.
Our presentation will provide clarification of standards for gift tax return adequate disclosure (case of first impression for Tax Court) and review how this informs return preparation and planning for defined value formula transactions.
Steve will provide analysis of cases on constructive dividends which include rental arrangements, reasonable compensation, and compensation for owner guarantees of corporation obligations.
Finally, Steve will review how transferee liability normally required a fraudulent (voidable) transfer under state law as well as a finding of federal liability, but a split decision of the Ninth Circuit ruled that no such finding is required regarding unpaid estate tax when distributions of bequeathed property are made to beneficiaries – no matter how far down the line they are. He will provide an overview of strategic implications if such a rule applies to your clients.
CLE
The live presentation of this webinar was approved for 1.5 hours of general CLE credit in California, Illinois, and Texas; 1.8 hours of general CLE credit in Missouri; and 1.5 hours of professional practice CLE credit in New York.
CLE credit is no longer available for this recording.
Presenter
For technical materials supporting the slides, please see Steve’s newsletter.
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