This new, simplified procedure is retroactive and effective for all taxable years for which a refund
with interest was paid after December 31, 1986.
Interest rates on overpayments
His involvement with interest on federal taxes dates back as far as 1955, when he was of counsel for the taxpayer in the consideration by the Supreme Court of the United States of Premier Oil Co.
942, where interest on a deficiency extinguished by a carryback was discussed along with interest in other situations; the term "restricted interest" was applied to refer to interest that was limited or restricted by some statutory prohibition of interest.
Terminating interest on the due date of the amount against which the credit is taken coordinates with section 6601(f), which deals with interest on underpayments satisfied by a credit.
Interest on federal tax deficiencies and overpayments
This negates any argument that interest expense may be netted
with interest income.
Allocating interest and other expenses under Section 864(e)
* Netting interest income
with interest expense subject to capitalization.
Filing of Form 3115 may be necessary by June 19, 1995 to obtain automatic approval (including audit relief) for changes to comply with final interest capitalization regulations
The IRS disallowed the netting of interest income
with interest expense.
Tax Court rules on interest income and expense netting for determining deduction allocated between parent and DISC
With interest rates at their lowest level in nearly 20 years (but expected to increase in the future), now may be the most opportune time to establish a grantor retained annuity trust (GRAT) or a grantor retained unitrust (GRUT).
Lower interest rates make GRATs and GRUTs and attractive tax planning technique
The IRS conceded that a MID for each gift should not be disallowed "solely because the transferred interests, when aggregated
with interests held by family members, would be a part of a controlling interest." In effect, the Service accepted the willing buyer-seller standard and agreed to value each gift separately.
Lifetime giving remains a powerful planning tool for family business owners
Interests in rental realty cannot be combined
with interests in other trade or business activities.
Passive loss relief for real estate professionals
Consequently, a MID will not be disallowed solely because a transferred interest, when aggregated with interests held by family members, would be part of a controlling interest.
93-12, that in valuing the shares, a MID will not be disallowed solely because a transferred interest, when aggregated with interests held by other family members, would be part of a controlling interest, it ruled that the swing vote attributes of each block should be considered in determining the value of each share.
"Swing vote" attributes of transferred stock: implications for minority interest discounts
93-12 merely held that "a minority discount will not be disallowed solely because a transferred interest, when aggregated
with interests held by other family members, would be part of a controlling interest." (Emphasis in original.)
Swing vote attribute affects value of gifted minority interest