2005 AP Bulletin Archive Page

Rejoice at the Good News! Corporate Death Proceeds Not Included in Valuing Decedent’s Stock: Estate of Blount v. Comm’r, 96 A.F.T.R.2d 2005-6795 (11th Cir. 2005)
Inflation and Cost of Living Adjustment Figures for 2006
Summary of Recent IRS Attacks on Abusive §412(i) Plans
Year-End Tax Planning Ideas
Brief Summaries

Summary of the §409A Proposed Regulations
Important Dates and Transitional Guidance under the §409A Proposed Regulations – Q&A
Nonqualified Deferred Compensation: Planning in Light of §409A
Section 409A’s Application to Split Dollar Plans
Roth 401(k)
Family Limited Partnerships: Kelley v. Comm’r, T.C. Memo 2005-235 (2005)
Brief Summaries

Proposed Deferred Compensation Regulations Released: §§ 1.409A-1 – 1.409A-6
Benefits Under Employer’s Disability Plan Are Taxable Income: Jerose v. Comm’r, T.C. Summary Opinion 2005-132 (September 6, 2005)
Wage Continuation Plans as an Executive Benefit
Brief Summaries

Strangi IV – Revenge of the Fifth – Thumbs Down for a Highly Anticipated Fifth Circuit Decision: Strangi v. Comm’r, 2005 U.S. App. LEXIS 14497 (5th Cir. 2005)
Time Is On Your Side, IRA Disclaimers Ruled Valid: Revenue Ruling 2005-36, 2005-26 I.R.B. 1368 (June 27, 2005)
Spreading the Wealth: Estate Planning for Family and Charity
Brief Summaries

Three New FLP Cases, Three Less Reasons to Smile: Abraham v. Comm’r, 408 F.3d 26 (1st Cir. 2005), Korby v. Comm’r, T.C. Memo 2005-102 and 2005-103 (May 10, 2005), Schutt v. Comm’r, T.C. Memo 2005-126 (May 26, 2005)
Summary of Circular 230
You’re Entitled to Your Opinion (Kinda) – Final Circular 230 Regulations on Tax Opinion Standards: Treasury Decision 9165 (December 17, 2004) and Treasury Decision 9201 (May 18, 2005)
Brief Summaries

Trust Owned Life Insurance on Trust Beneficiary Excluded from Estate: Private Letter Ruling 2005-18-005 (May 6, 2005)
Brief Summaries

IRS Issues New Life Insurance Valuation Safe-Harbor: Revenue Procedure 2005-25, 2005-17 I.R.B. (April 8, 2005)
Another FLP Goes Down: Bigelow v. Comm’r, T.C. Memo 2005-65 (March 30, 2005)
Sale of Policies Between Grantor Trust – Another Go-Around with the Same Result: Private Letter Ruling 2005-14-001 (April 8, 2005)
IRAs and Creditor Protection: The Supreme Court Weighs In, But Congress Gets the Last Word: Rousey v. Jacoway, 544 U.S. ____ (2005); Bankruptcy Abuse Prevention and Consumer Protection Act of 2005
Long Term Care Insurance for Owners of S Corporations
Brief Summaries

Tax Court Continues Its Crusade Against FLPs: Bongard v. Comm’r, 124 T.C. No. 8 (March 15, 2005)
Fool’s Gold IRS Ruling About VEBA-Owned Life Insurance Avoids the Crucial §419 Issue: Technical Advice Memo 2005-11-015 (March 18, 2005)
Final Regulations Eliminate the Use of Nonregistered Hedge Funds in Variable Contracts: Treasury Decision 9185, Repeal of Treasury Regulation § 1.817-5(f)(2)(ii) and (g) Example 3
Stock Option Update: U.S. v. Tuff, 95 A.F.T.R.2d 2005-1053 (February 4, 2005); Hubbard v. U.S., 95 A.F.T.R.2d 2005-1049 (January 13, 2005); IRS Announcement 2005-19, 2005-11 I.R.B. 744 (February 22, 2005); IRS Notice 2005-1, 2005-2 I.R.B. 274 (December 20, 2004)
Nonqualified Deferred Compensation: Planning in Light of § 409A and Notice 2005-1
Long Term Care Insurance as an Executive Perk in a C Corporation
Brief Summaries

Trust Lacks Insurable Interest: Chawla v. Transamerica Occidental Life Ins. Co., Civil Action No. 03-1215 (E.D. Va.) (February 3, 2005)
The Ties That Bind – Corporate Redemption is Compete: Hurst v. Comm’r, 124 T.C. No. 2 (February 2, 2005)
When Is “Basis” Not The Same As “Investment In the Contract?” Chief Counsel Advice 200504001 (January 28, 2005)
Life Insurance in a Credit Shelter Trust: Thinking Inside the Box
Brief Summaries

To Be Or Not To Be a Grantor Trust – Who Knows? Private Letter Ruling 2005-02-014 (January 14, 2005)
Trust-Owned Annuities Trigger Discussion of Non-Natural Person Rule and Other Issues: Private Letter Rulings 2004-49-011, -013, -014, -015, -016, and -017 (December 3, 2004)
Nonqualified Annuities and Trusts – Owner and Beneficiary Tips
Who Takes the Tax Hit? Tax Payment Provisions Do Matter: Private Letter Ruling 2004-52-010 (December 24, 2004)
Brief Summaries

Buy Sell Agreement Value ≠ Estate or Gift Tax Value: Estate of True v. Comm’r, 94 A.F.T.R.2d 2004-7039 (10th Cir. 2004)
IRS Issues More Guidance on Nonqualified Deferred Compensation: Notice 2005-1, 2005-2 I.R.B. (December 20, 2004)
Roth IRA Conversions Made a Little Easier: § 408A(c)(3)(C)(i)(II) (as amended by P.L. 105-206 and P.L. 105-277)
New Guidance on Bank-Owned Life Insurance: OCC Bulletin 2004-56 (December 7, 2004)
Corporation Must Report Income on Appreciated Assets Transferred to Limited Partnership When LP Interests are Transferred to Shareholders: Technical Advice Memorandum 2004-43-032 (October 22, 2004)
Tips for Structuring an Inheritance
Brief Summaries