Hogan Quoted in Tax Notes Article Regarding Proposed IRS Regulations
Andersen Tax Managing Director Jim Hogan was quoted in IRS Puzzles Over 199A Application to Charitable Remainder Trusts, a Tax Notes article written by Jonathan Curry. The article includes discussion and opinions from various tax practitioners on the Internal Revenue Service’s (IRS) proposed Section 199A regulations.
In the excerpt, Jim recognized that the IRS is open to consideration of whether charitable remainder trusts can be made eligible for the Sect. 199A deduction, but that they will need to be convinced further. He acknowledged that split interest trusts with business income which could initiate the deduction aren’t mainstream. Jim also mentioned there are a lot of issues associated with the proposed regulations, in particular the fact that on a normal basis charities don’t receive closely held property as the remainder because they would have to sell it immediately.
Jim Hogan, a member of Andersen Tax's US National Tax team, has over 35 years of legal and accounting experience and was most recently a Branch Chief in Internal Revenue Service’s (IRS) Office of the Chief Counsel. In that role, he had responsibility for all matters relating to estate, gift, and generation-skipping transfer tax issues.
August 10, 2018