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Monday, November 3, 2008

Where a Gift Tax Doesn’t Work

by taxnick on November 3, 2008

Here’s how the game is played (most commonly with an insurance trust). The trust provides that any time the trustee receives a gift to the trust, a notice is to be sent to the beneficiaries designated in the trust instrument. Those beneficiaries then have a limited time period from the date of the notice (frequently [...]

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IRS Notice 97-18 Clarifies Excise Tax Liability and Reporting Obligations

by taxnick on November 3, 2008

Venture capital and other securities investment funds organized as domestic partnerships (“Domestic Funds”) often have foreign persons as limited partners. In addition, domestic fund managers often establish investment partnerships outside the United States (“Offshore Funds”). In recent months, there has been substantial controversy surrounding: (i) the potential application of a 35 percent excise tax (the [...]

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