AICPA’s Comments on Notice 2011-66

On September 7, the AICPA Carryover Basis Task Force sent comments to the IRS on Notice 2011-66 making suggestions and requesting additional guidance on several issues, some of which are summarized below. They suggest a “policy of restraint” in auditing taxpayers having carryover basis issues for tax years after 3 years from the filing of the…

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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 Guidance Concerning the Generation-Skipping Transfer (GST) Tax

By Matthew J. Ahearn and Brian M. Malec This post continues on from our immediately previous posting concerning the Section 1022 election and filing requirements.  In this post, we will discuss the GST tax guidance in Notice 2011-66 (the “Notice”). A. Decedents Who Died in 2010. TRUIRJCA retroactively reinstated the GST tax for 2010, but…

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