Coming Soon: More Estate Tax Final Rules

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May 7 — Final guidance on several areas of estate tax could be released within the next six to eight weeks, an Internal Revenue Service official said.

Melissa C. Liquerman, branch chief in the IRS Office of the Chief Counsel (Passthrough and Special Industries), provided the update May 7 during a fiduciary income session at the American Bar Association Section of Taxation meeting.

Liquerman said “highly anticipated” final guidance on tax code Section 2704, which addresses family-owned business and family limited partnerships, will be among the regulations released (08 DTR S-13, 1/13/16).
“We really expect those out very, very shortly,” she said.

Liquerman said final regulations on Section 1022 also are close to completion. Proposed rules (REG-107595-11) were issued in May 2015 and the IRS received “very few comments,” so the final version will show little change, she said.
The regulations provide guidance for recipients of property with a decedent dying after Dec. 31, 2009 (90 DTR G-1, 5/11/15).

Other upcoming final regulations will focus on charitable managed trusts, claims against an estate, and treatment of trusts and retirement accounts. Liquerman said some of the guidance could come as soon as the next two weeks.

To contact the reporter on this story: Colleen Murphy in Washington at
To contact the editor responsible for this story: Brett Ferguson at

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