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  • A Bi-Monthly Electronic Publication for Section Members
  • February 2009

Group and Committee News

The Income and Transfer Tax Planning Group

In 2009 the Income and Transfer Tax Planning Group will host four periodic conference calls to discuss Group administrative matters, as well as substantive issues related to the five committees comprising the Group: the Estate and Gift Tax; Generation Skipping Transfers; Individual and Fiduciary Income Tax; International Tax Planning; and Tax Litigation and Controversy. The most recent call was sponsored on January 22nd by the Estate and Gift Tax Committee and covered several topics, including the issue of determining basis of assets in a grantor trust. (The Tax Litigation and Controversy committee sponsored a conference call late in 2008 covering Graegin loans.) The Group's call on March 18 will focus on issues relating to tax compliance, and will include an update on preparer penalties from Louis Mezzullo of Luce, Forward, Hamilton & Scripps, and a review of the most common pitfalls in preparing gift tax returns from Ronni G. Davidowitz of Katten Muchin Rosenman.

The Group also has a variety of offerings that will be presented at the Spring Symposia in Washington, DC. The Individual and Fiduciary Income Tax Committee will present a panel discussion on "Which Post-Death Events are Ignored under Sec. 2032, But Considered Under Sec. 2053." The Tax Litigation and Controversy Committee will present a program entitled "Practice Made Perfect: Lessons from the Tax Court Judiciary, the IRS, and Private Practice" that will address procedures of the Tax Court, and judges' perspectives on gift and estate tax matters, among other topics, as presented by Stephanie Loomis-Price, Baker Botts, Charles E. Hodges II, Chamberlain Hrdlicka, and an IRS official and Tax Court representative. In addition, the Group and its committees will sponsor a Group Roundtable at the Spring Symposia. Presenters will include Catherine V. Hughes, Office of Tax Policy, U.S. Treasury, who will discuss a variety of issues related to the process of issuing regulations. The Group will also cover special GST tax drafting and exercise issues related to powers of appointment, and will address recent developments, including: post- Knight fiduciary income tax deductions; the private trust company guidance and its general application; international estate planning under new administration; and reporting for offshore investments. Finally, the Group is the sponsor of a program entitled "The Rest of the Story: Income Tax Issues Related to Transfer Tax Planning with Grantor and Non-Grantor Trusts" presented by T. Randolph Harris, of McLaughlin & Stern, who will cover fiduciary tax issues related to sales to defective grantor trusts, insurance trusts, QPRTs, and other trusts.


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