The last few years have seen the proliferation of so-called section 643(b) trusts. Although there are various iterations of these trust arrangements, a common purpose seems to permeate each of them: ...
On November 7, 2024, the U.S. Internal Revenue Service (the IRS) released Form 15620, 1 which standardizes elections under section 83(b) of the Internal Revenue Code of 1986, as amended (the “Code,” ...
We once again want to bring to your attention the Internal Revenue Service’s (IRS) new favorite penalty provision: Internal Revenue Code (IRC) Section 6676. We have reported on this provision several ...
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