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A quarterly synopsis and analysis of the latest laws, court cases, IRS rulings, and planning developments. Designed and written for those actively engaged in advanced planning. Replaced by Bulletins in May 2004.

Brief 45 (04/02)

  • New Law Provides Tax Relief for Victims of Terrorism: Victims of Terrorism Tax Relief Act of 2001 (April 12, 2002)
  • Final Regulations Released on Excessive Compensation for Employees of Tax-Exempt Organizations: T.D. 8978 (January 22, 2002)
  • Net-Gift Rules Don't Reduce Value of Stock: Estate of Frank Armstrong Jr., et al. v. United States; No. 01-1305 (January 15, 2002)
  • Federal Taxation of IRA Distributions Overrides Community Property Law: Angela C. Morris v. Commissioner, T.C. Memo 2002-17 (January 16, 2002)
  • Full Value of Encumbered Property Included in Nonresident Alien's Gross Estate: Estate of Hon Hing Fung, et al. v. Commissioner, 117 T.C. No. 21 (Dec. 10, 2001)
  • Language Giving Trustee Discretion to Pay Insured's Estate Taxes With Life Insurance Proceeds Does Not Cause Estate Inclusion: Private Letter Ruling 2001-47-039 (August 21, 2001)
  • Employees Can Choose Whether to be Taxed on Employer-Paid Disability Premiums Absent a Cafeteria Plan? Not So Fast! Private Letter Rulings 2001-46-010, 2001-46-011, 2001-46-012
  • Stretch Planning for Nonqualified Annuities Opens Up: Private Letter Ruling 2001-51-038 (September 25, 2001)
  • Do the Gift-Splitting Rules Apply to the Donor's Deemed Additional Gift of GST Tax Paid on a Gift? Technical Advice Memorandum 2001-47-021 (July 31, 2001)
  • Same Challenges, New Entity—Are Family Corporations the Next Victims of I.R.S. Scrutiny? Field Service Advice Memorandum 2001-43-004 (July 5, 2001)
  • I.R.S. Updates Its No Ruling List: Revenue Procedure 2002-3; 2002-1 IRB 117
  • States May Not Offer EGTRRA Tax Relief

Brief 31 (03/99)

  • President's Budget Proposal Launches Frontal Attack on § 419 Welfare Benefits Plans
  • Tax Court Finds Partial Exchange of Annuity Contract Nontaxable under Section 1035(a)(3): Conway v. Commissioner, 111 T.C. No. 20
  • Real Estate Conveyances to Sham Trusts Set Aside: U.S. v. Dubey 98-2 U.S. Tax Cas. (CCH) ¶ 50,851
  • I.R.S. Issues Final Charitable Remainder Trust Regulations: Prop. Reg. §§ 1.664-1 Through 1.664-3 and 25.2702-1
  • New Proposed Section 79 Table I Rates Released by I.R.S.: Proposed Treasury Regulations § 1.79-3
  • Office of Comptroller of Currency (OCC) Approves Use of Life Insurance to Informally Fund a Bank's Deferred Compensation Plan: OCC Interpretative Letter No. 848
  • Estate Taxation of Property Transferred to a Former Spouse: Technical Advice Memorandum 98-26-002
  • "Flexible" Crummey Powers Guard Against Unwanted Withdrawals: Private Letter Ruling 98-34-004
  • An Exchange of One Jointly Owned Policy for Two Separately Owned Policies Is Not a Transfer for Value: Private Letter Ruling 98-52-041 (December 24, 1998)
  • Private Foundation's Receipt of a Donor's Retirement Account Proceeds Is Not Subject to Excise Tax: Private Letter Ruling 98-38-028 (September 18, 1998)
  • I.R.S. Rules on Transfer-for-Value Exception In a Family Partnership Context: Private Letter Ruling 99-03-020
  • Spouse's Revocable Annuity Interest In a GRAT Is Not a Qualified Interest: Private Letter Ruling 98-48-004
  • No Estate Inclusion of Insurance Proceeds Where Grantor Holds Limited Power to Replace Trustee: Private Letter Ruling 98-32-039

Brief 29 (09/98)

  • Including "Incompetency Provisions" Means Loss of Marital Deduction: Estate of Walsh v. Commissioner, 75 T.C.M. (CCH) 4605 (1998
  • Valuation Discounts Unavailable for Real Estate Held as California Joint Tenants With Rights of Survivorship: Young v. Commissioner, 110 T.C. No. 24 (1998)
  • Triple Split Dollar Buy-Sell: Don't Cut Yourself Slicing the Pie
  • Christal's So-Called "Trust" Is a Sham: Christal v. Commissioner, 76 T.C.M. (CCH) 97 (1998)
  • Surviving Spouse's Purchase of Remainder Interest in QTIP Results in Gift by Spouse: Revenue Ruling 98-8, 1998-6 I.R.B. 24
  • Controlling Trustee's Compensation and Lending Funds to Trust Do Not Cause Estate Inclusion: Private Letter Ruling 98-09-032
  • Private Letter Ruling Reiterates I.R.S. Position on Gifts of Nonqualified Stock Options: Private Letter Ruling 98-30-036
  • GST Tax Not Levied on GST Tax Paid by Estate for Direct Skip: Technical Advice Memorandum 98-22-001
  • Distributions From QDOT to U.S. Citizen Spouse Not Taxable: Private Letter Ruling 98-26-028
  • Gift to Club Qualifies for Annual Gift Tax Exclusion, But With a New Twist: Private Letter Ruling 98-18-042
  • Multi-Step 1035 Exchange Qualifies for Tax-Free Treatment: Private Letter Ruling 98-20-018

Brief 18 (02/96)

  • I.R.S. Notice on Section 419 Severance Pay Plans Revisited
  • Group Term and the Three Year Rule—Hays v. U.S., 95-2 USTC
  • Split Dollar and the Majority Stockholder
  • The I.R.S. Approves a Non-Qualified Deferred Compensation/401(k) Plan Combination—May Be Useful in Fine-Tuning Top Hat Employees' 401(k) Plan Contributions
  • I.R.S. Lets Wall Stand—Grantor Can Retain Right to Change Trustees Under Revenue Ruling 95-58
  • Creating Condition Is Not Enough to Exclude Trust Assets From An Estate

This publication is not intended as legal or tax advice. This information was compiled by The Northwestern Mutual Life Insurance Company. It is intended solely for the information and education and/or promotional purposes of Northwestern Mutual financial representatives and advisors with whom they work. It must not be used as a basis for legal or tax advice, and is not intended to be used and cannot be used to avoid any penalties that may be imposed on a taxpayer. Financial representatives do not give legal or tax advice. Taxpayers should seek advice based on their particular circumstances from an independent tax advisor. Tax and other planning developments after the original date of publication may affect these discussions.

© 2016 The Northwestern Mutual Life Insurance Company, Milwaukee, WI