goldberg urges the irs to address new state laws that pose a threat to the qtip marital decuction.
by seymour goldberg, cpa, mba (taxation), jd
the practitioner’s guide to the ira distribution rules under the secure act
lately, some clients and others have inquired about transferring their ownership in limited liability companies to trusts for estate planning and asset protection. i cautioned them that doing so could lead to complex tax and legal problems. to address this, i recently made a formal request to the irs for guidance on a unique situation.
read goldberg’s revenue ruling request here (pdf, 5 pages.)
specifically, i asked for clarification on how the marital deduction for qualified terminable interest property (qtip) applies when a trust owns only a portion of an llc. this is a relatively unexplored issue, and i sought the irs’s input to navigate it correctly.