Income Taxation of Estates and Trusts

This article addresses one aspect of the recent regulations promulgated under section 663 of the Internal Revenue Code of 1986 as amended (IRC or "Code"), specifically Treas. Reg. § 1.663(c)-5. Example 7 of the regulation provides that…

On October 22, 1986 the President signed into law the most sweeping changes in the income tax system in the United States for over 40 years: the Tax Reform Act of 1986 ("TRA '86"), which changes the name of the Internal Revenue Code of 1954…

"Oh go ahead and deduct it. They never audit 1041's anyway." Although you have probably heard it before, it may no longer be true and it may indicate a need for certain changes in focus in estate and trust tax planning.