Revenue Procedure 2011-41: Safe Harbor Guidance for 2010 Decedents Part 1 – Application of Section 1022

By Lauren Y. Detzel, Matthew J. Ahearn and Brian M. Malec This post kicks off our review of Revenue Procedure 2011-41, which was released simultaneously with IRS Notice 2011-66.  Rev. Proc. 2011-41 provides optional safe harbor guidance regarding basis issues under section 1022 for estates of decedents who died in 2010.  It’s important to note…

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Form 8939 Notice and Guidance

By Matthew J. Ahearn and Brian M. Malec On Friday, August 5, 2011, the IRS issued Notice 2011-66 and Rev. Proc. 2011-41 to provide guidance concerning the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (TRUIRJCA). Under TRUIRJCA, an election may be made to opt out of the estate tax and into…

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