updates

Website Updates

Sep-26-2021 - Our Table, Calculating the 2% Portion of Deferred Tax 1998 - 2022, is updated with the projected figures for 2022. Total tax deferred at the 2% rate will be $656,000.

Aug-26-2021 - IRS interest rates remain the same for the 4th quarter of 2021. See Revenue Ruling 2021-17.

Jun-14-2021 - Older links to the XML version of the electronic Code of Federal Regulations (eCFR) are being updated with direct links to the beta version of the current eCFR. We find the beta version to be more visually appealing and user friendly. 

May-27-2021 - IRS interest rates remain the same for the 3rd quarter of 2021. See Revenue Ruling 2021-10.

May-19-2021 - We are adding links to various electronic Code of Federal Regulations (eCFR) sections that are posted in beta format. See e.g. Procedural Part. 301 Regulations in eCFR (beta) and Reg. 301-7701-1 (eCFR beta). We believe that the beta version is more visually appealing and easier to use. 

Mar-02-2021 -  IRS interest rates remain the same for the second quarter of 2021. See Revenue Ruling 2021-6.

Feb-17-2021 - Links are added under IRS Resources to IRM 3.11.106, processing estate and gift tax returns, and IRM 3.11.106.18.8, processing Forms 4768 and section 6163 and 6166 elections.

Dec-04-2020 - IRS interest rates remain the same for the first quarter of 2021. See Revenue Ruling 2020-28. 

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Legal and Procedural Updates

Jun-28-2022 - IRS has proposed amendments to the Estate Tax Regulations for deductions under section 2053 [IRS-Reg-130975-08]. Among other proposed amendments, the allowable deductions for interest accrued more than 3 years after a decedent's date of death will be reduced to their "present values." This will impact certain section 6166 elections. Comments must be received by Sep-26-2022 to be considered.

May-20-2022 - IRS interest rates increase for the third quarter of 2022 beginning July 1. The regular non-corporate underpayment and overpayment interest rates will be 5%. See Revenue Ruling 2022-11.

May-04-2022 - IRS has proposed a rule regarding the anti-clawback provisions of Regulation 20.2010-1(c)(3) et seq. Written comments must be received by July 26, 2022.

Mar-28-2022 - The United States Tax Court has proposed amendments to its Rules of Practice and Procedure. Public Comments must be received by the Tax Court by May 25, 2022. Section 6166 Declaratory Judgment matters are covered in the Proposed Amendment to Rule 210 - Declaratory Judgment Actions (at page 103) - and in the Proposed Amendment to Rule 217 - Disposition of Actions for Declaratory Judgment (at page 110).

Feb-23-2022 - IRS interest rates increase for the second quarter of 2022 beginning April 1. The regular non-corporate underpayment and overpayment interest rates will be 4%. See Revenue Ruling 2022-05.

Dec-10-2021 - IRS has extended its temporary authorization to use electronic signatures on estate and gift tax returns (among others) through Oct-31-2023.

Nov-24-2021 - IRS interest rates remain the same for the first quarter of 2022 beginning January 1. See Revenue Ruling 2021-24.

Nov-16-2021 - Rev. Proc. 2021-45 provides the 2022 inflation-adjusted amounts for various Internal Revenue Code provisions. The section 6601(j) dollar amount for determining the  "2-percent portion" of tax deferred under a section 6166 election is $1,640,000 (item .51) and the 2022 basic exclusion amount is $12,060,000 (item .41). 

Oct-19-2021 - Footnote 1 in TD-9957 has been corrected to read "For an overview of the procedure applicable to a request for an estate tax closing letter before October 28, 2021, see part D of the Background and Explanation of Provisions of the proposed regulations." This correction is effective October 28, 2021 and is applicable as of September 28, 2021.

Sep-28-2021 - TD-9957 publishes final regulations establishing a $67 user fee for issuing estate tax closing letters, Letter 627. The effective date is October 28, 2021. This fee will also apply to estates that request additional closing letters for supplemental estate tax returns filed pursuant to Rev. Proc. 81-27. The public comments submitted in response to this proposed regulation can be found here.