IRS reverses prior position on estate tax ramifications of loan guarantees; remains silent as to gift tax implications.: An article from: The Tax Adviser

This digital document is an article from The Tax Adviser, published by American Institute of CPA's on August 1, 1994. The length of the article is 834 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.

From the supplier: A 1994 letter ruling has reversed the position of the IRS stated in a 1990 ruling that the gratuitous guarantee of a loan will affect the marital deduction, but the revised ruling did not address the gift tax issues in the 1990 ruling. The earlier ruling had claimed that the loan guarantee served to encumber property to be transferred at death, and the new ruling limited marital deduction reduction to instances when loan default was imminent. The IRS chose not to address the portion of the 1990 ruling that found the guarantee to be a gift currently taxable.

Citation Details
Title: IRS reverses prior position on estate tax ramifications of loan guarantees; remains silent as to gift tax implications.
Author: Carrine K. Reilly
Publication:The Tax Adviser (Magazine/Journal)
Date: August 1, 1994
Publisher: American Institute of CPA's
Volume: 25 Issue: n8 Page: 481(2)

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