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Robin Klomparens

Estate Planning on the 2010 Crazy Train

March 31, 2010

Power of Appointment Causes – Inclusion in Decedent’s Estate Technical Advice Memorandum 200907025 (TAM 200907025) Decedent was the sole beneficiary of a trust over which he was granted a power of appointment.  An issue arose as to whether the power of appointment was a general power of appointment for IRC section 2041 purposes.  The language […]

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Navigating Audit, Appeals and Litigation: The IRS’ Perspective

March 30, 2010

Power of Appointment Causes-Inclusion in Decedent’s Estate Technical Advice Memorandum 200907025 (TAM 200907025) Decedent was the sole beneficiary of a trust over which he was granted a power of appointment.  An issue arise as to whether the power of appointment was a general power of appointment for IRC section 2041 purposes.  The language of decedent’s […]

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Single Member LLCs and Estate and Gift Tax Treatment

February 28, 2010

This proposed topic is submitted on behalf of the Estate and Gift Tax Committee of the Taxation Section of the State Bar of California. Summary of Proposed Topic Under the “check-the-box” regulations, entity classification is simplified.  Under these rules, single member LLCs are, by default, disregarded for income tax purposes.  These rules, however, do not […]

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Special Needs Trusts

July 9, 2009

The main purpose for creating a special needs trust (SNT) is to preserve public benefits for disabled and/or aged beneficiaries.  Generally, public benefits that are “asset sensitive” are relevant to the planning of an SNT.  There are a number of reasons for creating an effective SNT, some of which include: The statutes and regulations relating […]

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