On June 17, 2024, the IRS published Revenue Ruling 2024-14 as part of a package it says will raise an additional $50 billion dollars of income taxes over the next decade from “basis-shifting transactions.”
SCOTUS Holds that Life Insurance Proceeds Used to Finance Stock Purchase Agreements Do Increase the Value of Closely Held Corporations for Estate Tax Purposes
On June 6, 2024, the Supreme Court of the United States ruled that life-insurance proceeds required to be used to redeem stock of a deceased shareholder must be included in the value of the company for purposes of determining the deceased shareholder’s gross estate.
Treasury Finalizes Regulations for Requesting an Extension of Time to Make Certain GST Elections
On May 3, 2024, the Treasury Department finalized regulations for the extension of time to make certain elections pertaining to the Generation Skipping Tax (GST) including elections for exemption allocations under section 2642(g).
IRS Seeks to Curtail Abusive Transactions Involving CRATs
On March 22, 2024, the Treasury Department published a proposed regulation relating to certain transactions involving Charitable Remainder Annuity Trusts (“CRATs”) investing in single premium immediate annuities (“SPIAs”). The rule would designate transactions seeking to exclude from income SPIA payments from a CRAT under Section 72(b)(2) of the Internal Revenue Code (the “Code”).
Louisiana Department of Revenue Issues Emergency Regulation on Louisiana Net Capital Gains Deduction
The Louisiana Department of Revenue has drafted an emergency regulation regarding the Louisiana net capital gains deduction, Louisiana Administrative Code 61:I.1312. The emergency regulation will be published in the January 20, 2024 issue of the Louisiana Register, but the rule is effective for all transactions occurring on or after January 1, 2024.
IRS Introduces Withdrawal Process For Wrongly-Claimed Employee Retention Tax Credit
On Thursday, the IRS introduced certain criteria that, if satisfied, allow a small business to withdraw a prior claim for the Employee Retention Tax Credit (ERC). Certain businesses paying wages to employees during the COVID-19 pandemic and experiencing a “significant decline in gross receipts” were eligible to apply for the ERC.
Louisiana State Tax Relief for Saltwater Intrusion
The Louisiana Department of Revenue followed the lead of the Internal Revenue Service and granted filing tax relief for taxpayers impacted by the saltwater intrusion emergency.
Tax Relief for Saltwater Intrusion
On Friday, September 29th, the IRS announced that tax relief will be available for individuals and businesses in Jefferson, Orleans, Plaquemines, and St. Bernard Parishes due to saltwater intrusion in the Mississippi River.