Taxation
Ca. Tax Lawyer Summer 2014, Volume 23, Number 2
Content
- A Proposal for Modifying the 36-Month Rule Imposed by Treasury Regulation Section 1.6050P-1(b)(2)(ii)(H)
- Bar Business Taxation Section Overview
- Contents
- Discussion of Common Tax Audit Issues Affecting California Corporate Taxpayers
- Masthead
- Message from the Chair
- Minutes from the 2014 Meeting of Eagle Lodge West, April 25-26, 2014
- Taxation Section 2013-2014 Leadership Directory
- Visiting the Committees
- Covered Gifts and Bequests: the Need for Guidance (5+ Years Out)
Covered Gifts and Bequests: The Need for Guidance (5+ Years Out)
By Patrick W. Martin1
EXECUTIVE SUMMARY
This paper makes some suggestions for guidance under section 2801 of the Internal Revenue Code,2 which has yet to be issued by the Internal Revenue Service ("IRS") and United States Department of the Treasury ("Treasury").
Section 28013 was passed into law in 2008 as part of the "HEART" Act.4 In short, the statutory provision provides that "any United States citizen or resident" who receives "any covered gift or bequest"5 is subject to a tax (currently 40%6) on the value of such gift or bequest.