Transfer Tax Research Paper

Hoffman, W., Maloney, D., Raabe, W., & Young, J. (2013). Federal Taxation Comprehensive Volume. (36 ed.). Ohio: South-W

The resulting change equates to roughly 500K increase in pre-tax income. The allowance would have been $8,531,577.60 if they had kept the same ratio from 2003 in 2004.

3 Arthur B. Kennickell. “Ponds and Streams: Wealth and Income in the U.S., 1989 to 2007,” Federal Reserve. 2009. Accessed January 13, 2013.

"In 2004, property tax collections in the U.S. exceeded $300 billion. Property taxes are responsible for approximately 72% of all local tax revenues, representing the most important tax revenue source for local governments" (as cited in Shan, 2010, p.195).

The Internal Revenue Service (“IRS”) issued regulations called the “Clifford Regulations” in 1946. The Clifford Regulations formed the basis for Congressional codification of the grantor trust rules in current Subpart E in 1954. While income tax rates today are not as far apart as they were in 1954, and even though the IRS targeted abuses with the grantor trust rules, those rules offer favorable opportunities for taxpayers today.

Parent Corporation owns 85% of the common stock and 100% of the preferred stock of Subsidiary Corporation. The common stock and preferred stock have adjusted bases of $500,000 and $200,000, respectively, to Parent. Subsidiary adopts a plan of liquidation on July 3 of the current year, when its assets have a $1 million FMV. Liabilities on that date amount to $850,000. On November 9, Subsidiary pays off its creditors and distributes $150,000 to Parent with respect to its preferred stock. No cash remain to be aid to Parent with respect to the remaining $50,000 of its liquidation preference for the preferred stock, or with respect to any common stock. In each of Subsidiary’s tax years, less than %10 of its gross

Decedent made a transfer within 3 years of death. Under Section 2035(a), nothing is included in Decedent’s gross estate, because it’s a cash gift. However, under Section 2035(b), the amount of the gross estate shall be increased by the amount of any tax paid on any gift made by the decedent during the 3-year period ending on the date of the decedent’s death. So the amount of gift tax of this gift the decedent paid is included in his gross estate.

Charley Long, a truck driver, works for a seafood company in Mobile, Alabama. Charley helps to deliver fresh seafood to customers from Mobile with the company’s truck. Charley leaves Mobile every weekday at 4:00pm and arrives his last stop at 12:00 midnight. It’s up to Charley whether to drive straight back or spend a night along the road as Charley’s company doesn’t reimburse any his lodging and food expense. Charley sometimes sleeps in his cab in which is equipped with sleeping facilities, having one meal on his way. Occasionally, Charley stays in motels during which he will eat two meals. The IRS disallowed all his expenses generated in his trips, as IRS believes that his expenses are personal expenses.

They appropriately reported this money in their 1964 personal income tax return as other income.

Facts: Murray Taxpayer was previously employed by a company who was illegally dumping chemicals into a river. Murray had knowledge concerning these illegal activities of his employer and made an ethical decision to report this to the Environmental Protection Agency. Upon inspection, the Environmental Protection Agency determined that Murrays employer was in fact illegally dumping and was appropriately fined for the charges. Murray’s employer reacted to his whistleblowing by firing him and making deliberate efforts to prevent Murray from gaining employment elsewhere. Murray then sued his former employer for damaging

1. All distributions (excluding reasonable salary) to Paula and Mary will be taxed as dividends to them. And the corporation could not deduct this part of distribution.

The most interesting category was the government grants (contributions) in the amount of $186,244,548.This amount makes up 77% of the revenue from Contributions, Gifts, Grants and Other Similar Amounts (see Figure 2). According to Barr and

Form a Powerful Coalition - Rossotti used a phased approach to map out his strategic plan for transforming the IRS. He used experts to help him define the organization’s archirEtecture and outline the transformation program. He then used IRS employees to develop a more detailed plan, which included a communication plan to help employees become aware that a major change was occurring to build commitment and buy-in.

The United States tax system is in complete disarray. Republicans and Democrats agree that the current tax code is complex, unfair, and costly. The income tax system is so complex; the IRS publishes 480 tax forms and 280 forms to explain the 480 forms (Armey 1). The main reason the tax system is so complex is because of the special preferences such as deductions and tax credits. Complexity in the current tax system forces Americans to spend 5.4 billion hours complying with the tax code, which is more time than it takes to manufacture every car, truck and van produced in the United States (Armey 1). Time is not the only thing that is lost with the current tax system; Americans also lose

Obviously, most Americans don't have a substantial estate portfolio. However, a lot of them can enjoy huge budgetary advantage and as well give a beneficent advantage to the public.