Jan 1, 2009 12:00 PM

By Radd L. Riebe

Wow! During 2008 we witnessed $4 a gallon gasoline, a mortgage industry meltdown, the Dow Jones Industrial Average fall from approximately 13,000 to 8,000, and the election of a new president; an African American, no less. And amidst all of these historic firsts, we may be experiencing the best of times for gift tax planning from a valuation perspective, because transfers may be accomplished at lower values.

First, though, let's note the good news: Discounts are actually holding, at long last. After years of Internal Revenue Code Section 2036¹ losses by taxpayers, in early 2008, the taxpayer won a significant victory in Estate of Mirowski.² A limited liability company established with a legitimate and significant non-tax reason satisfied the “bona fide sale” exception for application of IRC Section 2036(a). The enumerated legitimate non-tax purposes in Mirowski were:

Topics of Interest

Estate Tax	Donor Advised Funds
GSTs	Family Offices
Private Foundations	Life Insurance
2010 Tax Act News	Industry Trends Surveys

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Topics of Interest

Estate Tax	Donor Advised Funds
GSTs	Family Offices
Private Foundations	Life Insurance
2010 Tax Act News	Industry Trends Surveys

E-Newsletter Signup

2011 Trust Glossary

Click here to download the 2011 Trust Glossary

50 Years Ago This Month

Click here to read the issue.

50 years ago, in May 1962, we featured articles such as: "Future of Canadian Trusteeship" by Arthur H. Mingay", "Training Trust Employees" by Ian M. Marr, "What is a Trust Officer?" by Eric J. Brown, and "Selling Services" by Donald I. Webb.

Conrad Teitell's Guide to Tax Benefits For Charitable Gifts

Click here to view the most up to date guide (September 2011)

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