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This Directive provides that LB&I examiners should not challenge the eligibility of an insurance company’s guaranteed minimum benefit (“GMxB”) Hedges (defined below) to qualify as hedging transactions under Treas. Reg. § 1.1221-2(b).

For estates of decedent nonresidents not citizens of the United States, the Estate Tax is a tax on the transfer of U.S.-situated property, which may include both tangible and intangible assets owned at the decedent’s date of death.

Get information on how the estate tax may apply to your taxable estate at your death.

An introduction to the estate administration exception to indirect self-dealing under Treas. Reg. 53.4941(d)-1(b)(3).

Steps to take after a disaster so taxpayers can reconstruct their records and prove loss of personal-use and business property.

Meaning of capital gains and losses included in gross investment income for purposes of the tax in Code section 4940.

Alphabetical index of retirement plan topics.

The Moving Ahead for Progress in the 21st Century Act changed many items for single-employer defined benefit plans, including giving significant funding relief by allowing plans to use a 25-year average interest rate. At the same time, MAP-21 increased the annual Pension Benefit Guaranty Corporation premium each year beginning in 2013.

Abusive Trust Tax Evasion Schemes - Special Types of Trusts

Rents from the lease of personal property are not excludable from unrelated business taxable income under Section 512(b)(3), unless the personal property is leased with real property and the rent attributable to the personal property is an incidental amount of the total rents received or accrued under the lease, as determined at the time the personal property is first placed in service. If more than 50% of the total rental income under a lease is attributable to personal property, then none of the income received or accrued under the lease is excludable from unrelated business taxable income under Section 512(b)(3).