When using life insurance to fund the redemption of the stock of a deceased shareholder in a closely held corporation, structuring the ownership of the insurance is critical and, very often, using an “insurance partnership” can be advantageous.
Chuck and Michael opine on Warne v. Commissioner, TC Memo 2021-17, a case that addressed, among other issues, an estate tax charitable deduction.
Learn about the tax basis capital account reporting requirements.
There are several provisos contained in Notice 2021-13, 2021-6 IRB 1 with regard to the penalty waivers.
Chuck and Michael highlight important changes to the final regulations under the business interest deduction limitations of §163(j).
Learn about an item of taxpayer relief from the §163(j) business interest deduction limitation regulations.