Section Newsletters

Articles From Michael Cyrs

IRS still not charitably driven when clients steer IRAs to trusts By Michael Cyrs Trusts and Estates, March 2007 The Internal Revenue Service is still a miser when it comes to trusts and individual retirement accounts. In a recent internal legal memorandum (Internal Legal Memorandum 200644020 “ILM”) the Internal Revenue Service (“Service”) concluded that a transfer of an individual retirement account (“IRA”) to charity to satisfy a legacy from a trust was taxable to the trust as income in respect of the decedent under Internal Revenue Code Section 691(a)(2).
Mooove over Illinois, Wisconsin Real Estate Sheds Probate Harness By Michael Cyrs Trusts and Estates, March 2007 Wisconsin recently passed legislation permitting owners of real property to avoid probate simply by naming a beneficiary to inherit the real estate.
Estate tax legislation scheduled for Senate debate in May 2006 By Michael Cyrs Trusts and Estates, May 2006 Senate Majority Leader Bill Frist (R-TN) has scheduled permanent estate tax repeal legislation for debate in May of this year.
True to form, the Tax Court overrides formula price in family business buy-sell agreements By Michael Cyrs Trusts and Estates, March 2005 In the October 2004 newsletter, members of this Section Council highlighted two recent cases (Estate of Blount and Estate of Smith) wherein the Internal Revenue Service ("Service") successfully applied Internal Revenue Code Section 2703 principles to disregard the restrictions provided under a buy-sell agreement between shareholders and to disregard restrictive provisions of a family limited partnership, both resulting in significantly higher valuations of the underlying property for estate and gift tax purposes.

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