A buy-out agreement that provides for the installment purchase of a decedent's stock can protect the availability of the Section 6166 election to defer the payment of estate tax attributable to a closely held business interest.
The South Carolina estate tax, S.C. Code Ann.§ 12-16-10 et seq, imposes a tax on the transfer of the estate of both residents and nonresidents. Id., § 12-16-510, 520. (The South Carolina Estate Tax Act also imposes a tax on the transfer of the estate of aliens and includes a generation-skipping transfer tax. This article does not address these issues.) On its face, the tax appears straightforward and, in effect, represents a relatively fair death tax approach. Nevertheless, it contains unexpected nuances.
The Florida estate tax imposes a tax upon the transfer of estates of both resident and nonresident decedents. On its face, the tax appears straightforward and, in effect, has represented a fair death tax approach. Nevertheless, the Florida estate tax contains unexpected nuances.
As client pressure to minimize legal fees continues to mount, estate planning lawyers must reexamine their billing practices. Increased computer capability has led to drafting efficiencies, which have allowed estate planners to focus more on estate tax planning and less on actual drafting. This approach affects a traditional strategy used to mitigate tfle burden of estate planning fees: deducting a portion of those fees for income tax purposes.
Underlying the basic premise of the Internal Revenue Code-the desire to raise revenue for the federal government-is a congressional desire to achieve policy objectives through the enactment of specific tax legislation.