691(c) allows the IRD recipient an income tax deduction for estate tax paid that is attributable to inclusion of net IRD in the decedent's gross estate
In 2001, the second highest percentage of nonresident alien estates was in the gross estate
category of $60,000 under $100,000, with 24.
2040 would have included only one-half of the property in the decedent's gross estate
In 1995, 78,023 individuals died with gross estates
at or above the Federal estate tax filing threshold of $600,000.
The Tax Court held that the trust was fully includible in the decedent's gross estate
25) Finally, this article examines South Dakota's DAPT statutes and discusses whether a settlor's transfers to a South Dakota DAPT could be considered completed gifts for federal gift tax purposes and whether the transferred assets could be excluded from the settlor's gross estate
for federal estate tax purposes.
By transferring such property, taxpayers can remove substantially appreciating assets from their estates while paying gift tax on the transfers to reduce the value of their gross estates
For estate tax purposes, the value of property included in gross estate
is fair market value (FMV), defined as "the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of all relevant facts," according to Federal Tax Regulation 20.
Set forth in Table 1 are the effective tax rates and charitable contributions for all estates reporting gross estates
of $5 million or more from 2002 through 2006.
Conversely, decedents employed in each of the other broad occupation groups had average gross estates
below the overall average, $4.
and established domicile, all of their assets, no matter where located, will be includible in their Federal gross estates
In this article, liquid assets include cash, State and local bonds, Federal Government bonds, publicly traded stock, and insurance on the life of the decedent owned by the decedent and included in the total gross estate