Income and Transfer Tax Planning Group (TE)
Tax Litigation and Controversy Committee
Recorded on January 23, 2019
John Porter of Baker Botts (Houston, TX), Caryn I. Friedman of Ernst & Young LLP (Washington, DC) and Emily A. Plocki of Venable LLLP (Washington, DC) discuss timely topics to kick off the New Year.
John Porter’s discussion addresses current issues and trends in the transfer tax controversy arena at the audit level, appeals and in litigation, inclusive of transfer of interests in closely-held entities, use of formula clauses and split-dollar life insurance.
Caryn Friedman follows John and addresses estate planning after IRC Section 965 transition tax inclusive of the key issues and traps for the unwary with respect to estate planning that may trigger or accelerate payment of transition tax.
Emily Plocki rounds out the hour by providing an overview of the application and availability of 9100 relief in the estate, gift and generation-skipping transfer tax areas as well as income tax and miscellaneous applications.
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