{"id":1599,"date":"2013-08-12T01:24:00","date_gmt":"2013-08-12T05:24:00","guid":{"rendered":"https:\/\/actec.matrixdev.net\/?post_type=capital-letter&p=1599"},"modified":"2024-04-17T17:13:54","modified_gmt":"2024-04-17T21:13:54","slug":"priority-guidance-plan-published-commissioner-nominated","status":"publish","type":"capital-letter","link":"https:\/\/actec.matrixdev.net\/capital-letter\/priority-guidance-plan-published-commissioner-nominated\/","title":{"rendered":"Priority Guidance Plan Published, Commissioner Nominated"},"content":{"rendered":"\n

The 2013-2014 Treasury-IRS Priority Guidance Plan contains no estate tax surprises, while the President nominates a new Commissioner of Internal Revenue.<\/strong><\/em>
<\/p>\n\n\n\n

Dear Readers Who Follow Washington Developments:<\/p>\n\n\n\n

On August 9, 2013, Assistant Secretary of the Treasury for Tax Policy Mark Mazur, Acting Commissioner of Internal Revenue Daniel Werfel, and IRS Chief Counsel Bill Wilkins released the\u00a02013-2014 Priority Guidance Plan<\/a>.\u00a0 Meanwhile, on August 1, President Obama had nominated a new Commissioner of Internal Revenue.<\/p>\n\n\n\n

2013-2014 PRIORITY GUIDANCE PLAN<\/strong><\/p>\n\n\n\n

The 2013-2014 Priority Guidance Plan contains 324 projects (up only slightly from 317 last year) described as \u201cpriorities for allocation of the resources of our offices during the twelve-month period from July 2013 through June 2014 (the plan year).  The plan represents projects we intend to work on actively during the plan year and does not place any deadline on completion of projects.\u201d<\/p>\n\n\n\n

The Plan contains the following 11 items under the heading of \u201cGifts and Estates and Trusts\u201d:<\/p>\n\n\n\n

    \n
  1. Final regulations under\u00a0\u00a767<\/a>\u00a0regarding miscellaneous itemized deductions of a trust or estate.\u00a0Proposed regulations<\/a>\u00a0were published on September 7, 2011.<\/li>\n\n\n\n
  2. Guidance concerning adjustments to sample charitable remainder trust forms under\u00a0\u00a7664<\/a>.<\/li>\n\n\n\n
  3. Guidance concerning private trust companies under \u00a7\u00a7671<\/a>,\u00a02036<\/a>,\u00a02038<\/a>,\u00a02041<\/a>,\u00a02042<\/a>,\u00a02511<\/a>, and\u00a02601<\/a>.<\/li>\n\n\n\n
  4. Regulations under\u00a0\u00a71014<\/a>\u00a0regarding uniform basis of charitable remainder trusts.<\/li>\n\n\n\n
  5. Revenue Procedure under\u00a0\u00a72010(c)<\/a>\u00a0regarding the validity of a QTIP election on an estate tax return filed only to elect portability.<\/li>\n\n\n\n
  6. Final regulations under\u00a0\u00a72032(a)<\/a>\u00a0regarding imposition of restrictions on estate assets during the six month alternate valuation period.\u00a0Proposed regulations<\/a>\u00a0were published on November 18, 2011.<\/li>\n\n\n\n
  7. Guidance under\u00a0\u00a72053<\/a>\u00a0regarding personal guarantees and the application of present value concepts in determining the deductible amount of expenses and claims against the estate.<\/li>\n\n\n\n
  8. Regulations under\u00a0\u00a72642<\/a>\u00a0regarding the allocation of GST exemption to a pour-over trust at the end of an ETIP.<\/li>\n\n\n\n
  9. Final regulations under\u00a0\u00a72642(g)<\/a>\u00a0regarding extensions of time to make allocations of the generation-skipping transfer tax exemption.\u00a0Proposed regulations<\/a>\u00a0were published on April 17, 2008.<\/li>\n\n\n\n
  10. Regulations under\u00a0\u00a72704<\/a>\u00a0regarding restrictions on the liquidation of an interest in certain corporations and partnerships.<\/li>\n\n\n\n
  11. Guidance under\u00a0\u00a72801<\/a>\u00a0regarding the tax imposed on U.S. citizens and residents who receive gifts or bequests from certain expatriates.<\/li>\n<\/ol>\n\n\n\n

    Most of these items have been carried over from past years.\u00a0 In fact, the average length of time these 11 items have been on the Priority Guidance Plan is about 6\u00bc years.\u00a0 Except for items 5 and 8, these projects were described and analyzed in\u00a0Capital Letter No. 32<\/a>.\u00a0 There are no significant updates for those nine projects.<\/p>\n\n\n\n

    Item 5: The Validity of QTIP Elections in Portability-Only Returns<\/p>\n\n\n\n

    Item 5 is the only new topic this year and represents an issue highlighted by the enactment of \u201cportability\u201d for two years in the 2010 Tax Act<\/a> and permanently in the 2012 Tax Act<\/a>.  It was one of many topics that ACTEC recommended in its letter of April 30, 2013.<\/p>\n\n\n\n

    The issue is traceable to Rev. Proc. 2001-38, 2001-24 I.R.B. 1335, which announced circumstances in which the IRS \u201cwill disregard [a QTIP] election and treat it as null and void\u201d if \u201cthe election was not necessary to reduce the estate tax liability to zero, based on values as finally determined for federal estate tax purposes.\u201d  The revenue procedure states that it \u201cdoes not apply in situations where a partial QTIP election was required with respect to a trust to reduce the estate tax liability and the executor made the election with respect to more trust property than was necessary to reduce the estate tax liability to zero.\u201d  The revenue procedure states that it \u201calso does not apply to elections that are stated in terms of a formula designed to reduce the estate tax to zero.\u201d  Thus, the paradigm case to which the Rev. Proc. 2001-38 applies is the case where the taxable estate would have been less than the applicable exclusion amount anyway, so the estate would not be subject to federal estate tax, but the executor listed some or all of the trust property on Schedule M of the estate tax return and thus made a redundant QTIP election.<\/p>\n\n\n\n

    Rev. Proc. 2001-38 is a relief measure.  The transitional sentence in Rev. Proc. 2001-38 between the summary of the background law and the explanation of the problem states that \u201c[t]he Internal Revenue Service has received requests for relief in situations where an estate made an unnecessary QTIP election.\u201d<\/p>\n\n\n\n

    With portability of unused unified credit from a deceased spouse to a surviving spouse, which was made permanent in the 2012 Tax Act<\/a>, an estate tax return to elect portability might be filed that is not necessary for estate tax purposes because the value of the estate is below the filing requirement.  For such a return, a QTIP election is obviously not required to reduce the federal estate tax, because there will be no tax in any event.  But, in approaches to portability widely discussed among commentators, a QTIP election might still be made to support a reverse-QTIP election for GST tax purposes, to gain a second basis step-up at the death of the surviving spouse, or for some other reason.  The existence of Rev. Proc. 2001-38 raises the question whether such a QTIP election might be treated as an election that \u201cwas not necessary to reduce the estate tax liability to zero\u201d and therefore as \u201cnull and void.\u201d<\/p>\n\n\n\n

    Rev. Proc. 2001-38 goes on to state that \u201c[t]o establish that an election is within the scope of this revenue procedure, the taxpayer must produce sufficient evidence to that effect.  For example, the taxpayer [the surviving spouse or the surviving spouse\u2019s executor] may produce a copy of the estate tax return filed by the predeceased spouse\u2019s estate establishing that the election was not necessary to reduce the estate tax liability to zero.\u201d  Thus, it might be thought that Rev. Proc. 2001-38 is simply inapplicable if the surviving spouse or the surviving spouse\u2019s executor does not affirmatively invoke it.  But the example of \u201cproduc[ing] a copy of the estate tax return filed by the predeceased spouse\u2019s estate establishing that the election was not necessary to reduce the estate tax liability to zero\u201d is a bit troubling in the portability context, because it is exactly that return that will have elected portability and therefore will be the basis for any application of portability by the surviving spouse or the subsequent executor, and any return filed only to elect portability will necessarily show that the QTIP election was not necessary to reduce estate tax.<\/p>\n\n\n\n

    Nevertheless, the \u201crelief\u201d nature and origin of Rev. Proc. 2001-38, the likelihood that a revenue procedure announcing the Service\u2019s administrative forbearance cannot negate an election clearly authorized by statute, and the unseemliness of denying the collateral benefits of a QTIP election to smaller estates while allowing it to larger estates all suggest that a QTIP election should be respected in such a case.  This view is reinforced by the explicit reference in Reg. \u00a720.2010-2T(a)(7)(ii)(A)(4<\/em>) to QTIP elections in returns filed to elect portability but not otherwise required for estate tax purposes, a reference that would make no sense if any such QTIP election were necessarily \u201cnull and void.\u201d  Clarifying that result is evidently what this new item on the Priority Guidance Plan is about.  It is not always the case that the appearance of a project on the Priority Guidance Plan makes it clear what the outcome of the project will be, but it is clear in this case.<\/p>\n\n\n\n

    On the other hand, Rev. Proc. 2001-38 could appear, in effect, to make the consequences of a QTIP election elective on the basis of what could be very long hindsight, permitting the QTIP election to be repudiated even on the estate tax return filed after the surviving spouse\u2019s death.  That actually seems to have been a potential result ever since Rev. Rul. 2001-38 was published, and it is not really changed by portability.  If there is any suspense in the current guidance project, it is in seeing if and how that dilemma is acknowledged and addressed.<\/p>\n\n\n\n

    Item 8: Allocation of GST Exemption at the End of an ETIP<\/p>\n\n\n\n

    Item 8 was new last year (as item 7).  Despite the vague reference to \u201ca pour-over trust at the end of an ETIP,\u201d we know that it is probably aimed, at least in part, at the continuing trusts that are sometimes provided for at the end of the annuity period in a GRAT.  This is because the public correspondence suggests that this project is derived from a request for guidance from the AICPA, first made in a letter dated November 10, 2004, and reprised in a letter dated June 26, 2007, which stated:<\/p>\n\n\n\n

    The issues presented here are best illustrated by considering the following fact pattern:<\/p>\n\n\n\n

    Taxpayer creates an irrevocable trust, Trust Z, in which a qualified annuity interest (as defined in section 2702(b)) is payable to the taxpayer or his estate for 10 years.  Upon the termination of the annuity interest, Trust Z is to be separated into two trusts, Trust A and Trust B. Trust A is for the exclusive benefit of Taxpayer\u2019s children and grandchildren.  Trust B is for the exclusive benefit of Taxpayer\u2019s children.  Trust A is to receive from Trust Z so much of the Trust Z\u2019s assets as is equal to Taxpayer\u2019s remaining GST exemption, if any. Trust B is to receive from Trust Z the balance of Trust Z\u2019s assets, if any, after funding Trust A.  The taxpayer is alive at the end of the 10 years.<\/p>\n\n\n\n

    Presumably, the transfer to Trust Z is an indirect skip to which GST exemption will be automatically allocated at the end of the ETIP.  Will the automatic allocation rules apply to all the assets remaining in Trust Z at that time?  If so and if the taxpayer wants to allocate GST exemption only to the assets going to Trust A, the taxpayer should timely elect out of the automatic allocation rules of section 2632(c), and then affirmatively allocate GST exemption only to the assets going into Trust A at the end of the ETIP.  Is that possible?<\/p>\n\n\n\n

    In the alternative, the automatic allocation rules may apply only to the transfer going into Trust A because Trust B is not by definition a GST trust.  Because of the application of the ETIP rules, the transfer from the taxpayer for GST purposes would occur only at the time that the assets are funded into Trust A.  If that is the case, then the taxpayer does not need to do anything affirmatively to ensure that GST exemption is allocated to Trust A and not Trust B as he or she desires.<\/p>\n\n\n\n

    It has been our experience that many trusts are structured in a manner similar to the above referenced fact pattern.  By letter dated November 10, 2004, the AICPA submitted comments on the proposed regulations on electing out of deemed allocations of GST exemption under section 2632(c).  In that letter, guidance was requested on these issues.  The preamble to the final regulations (T.D. 9208) acknowledged this request for the inclusion in the regulations of an example addressing the application of the automatic allocation rules for indirect skips in a situation in which a trust subject to an ETIP terminates upon the expiration of the ETIP, at which time the trust assets are distributed to other trusts that may be GST trusts.  According to the preamble, the Treasury Department and the Internal Revenue Service believed that this issue was outside the scope of the regulation project and would consider whether to address these issues in separate guidance.<\/p>\n\n\n\n

    In addition to the clues in this AICPA letter to what the new guidance project might be aimed at, there are two other lessons to be learned from the letter, one discouraging and one encouraging.  The discouraging lesson is that it can sometimes take up to eight years or longer for a relatively straightforward suggestion about a common and innocent technique to be acknowledged in a formal guidance project, although we do know that some of these suggestions receive thoughtful attention and preliminary work even without formal acknowledgment.  The encouraging lesson is that perseverance pays off, in this case the perseverance of our friends at the AICPA.  The letter in which ACTEC suggested a clarification of Rev. Proc. 2001-38 as a Priority Guidance Plan project also recommended 11 other topics, some of which ACTEC has proposed in various contexts for a number of years, but none of which were picked up this time.  Even so, ACTEC and those Fellows who work hard to identify and draft such recommendations can be encouraged that patience is often rewarded after all.  And that is a good lesson to keep in mind while turning to the next subject related to the Priority Guidance Plan.<\/p>\n\n\n\n

    The Omission of Decanting<\/p>\n\n\n\n

    The\u00a02011-2012 Priority Guidance Plan<\/a>\u00a0included, as item 13, \u201cNotice on decanting of trusts under \u00a7\u00a72501 and 2601.\u201d\u00a0 This project was new in 2011-2012, but it had been anticipated for some time, at least since the publication at the beginning of 2011 of\u00a0Rev. Proc. 2011-3, 2011-1 I.R.B. 111<\/a>, in which new sections 5.09, 5.16, and 5.17 included decanting among the \u201careas under study in which rulings or determination letters will not be issued until the Service resolves the issue through publication of a revenue ruling, revenue procedure, regulations or otherwise.\u201d (Sections 5.01(16), (23), and (24) of\u00a0Rev. Proc. 2013-3, 2013-1 I.R.B. 113<\/a>, continue this designation.)<\/p>\n\n\n\n

    On December 20, 2011, the IRS published Notice 2011-101, 2011-52 I.R.B. 932<\/a>, asking for comments from the public on the tax consequences of decanting transactions \u2013 the transfer by a trustee of trust principal from an irrevocable \u201cDistributing Trust\u201d to another \u201cReceiving Trust.\u201d  The Notice listed 13 facts and circumstances as examples of the factors that might affect the tax consequences and on which it was seeking comments.  ACTEC submitted comments, including a proposed revenue ruling, on April 2, 2012.<\/p>\n\n\n\n

    But decanting was omitted from the\u00a02012-2013 Priority Guidance Plan\u00a0and again this year.\u00a0 Technically, the 2011-2012 Plan promised only a \u201cNotice,\u201d and\u00a0Notice 2011-101<\/a>\u00a0was indeed that.\u00a0 So the project could not just be carried over; it would have to be reformulated and refocused.\u00a0 Many readers will think that something like \u201cGuidance on decanting\u201d would work fine.\u00a0 But, as noted above in the discussion of GST exemption allocations at the end of an ETIP, it is not easy to get a project on the Priority Guidance Plan, and furthermore, the absence of such a formal project does not mean that those responsible for preparing the ultimate guidance are not thinking about decanting issues, including those analyzed in ACTEC\u2019s comments.<\/p>\n\n\n\n

    A Section 501(c)(4) Aside<\/p>\n\n\n\n

    In contrast to the typical complicated and prolonged process to get a project on the Priority Guidance Plan, sometimes it\u2019s easy and quick.  A case in point, selected not really at random, is item 3 under the heading of \u201cExempt Organizations,\u201d new this year, described as \u201cGuidance under \u00a7501(c)(4) relating to measurement of an organization\u2019s primary activity and whether it is operated primarily for the promotion of social welfare, including guidance relating to political campaign intervention.\u201d  Although the prose is labored \u2013 there seem to be just a few too many words \u2013 the source and purpose are unmistakable to any tax observer who has not been on the back side of the moon since May 3.  This is a part of the response to the uproar that erupted on that day about the Internal Revenue Service\u2019s handling of applications for recognition of tax exemption, especially by applicants seeking recognition as \u201csocial welfare organizations\u201d under section 501(c)(4)<\/a> that have or appear to have a political agenda or motivation or an interest in the outcome or conduct of political campaigns.<\/p>\n\n\n\n

    The overall discussion is way too broad and fluid to be summarized fairly in a Capital Letter.  Both uninformed accusations and uninformed defenses seem to have obscured the sunshine our government should have.  Aside from exceedingly difficult process and personnel issues, this discussion has highlighted the anomaly that section 501(c)(4)(A)<\/a> exempts \u201c[c]ivic leagues or organizations not organized for profit but operated exclusively for the promotion of social welfare,\u201d Reg \u00a71.501(c)(4)-1(a)(2)(i) holds that \u201c[a]n organization is operated exclusively for the promotion of social welfare if it is primarily engaged in promoting in some way the common good and general welfare of the people of the community,\u201d and Reg \u00a71.501(c)(4)-1(a)(2)(ii) adds for good measure that \u201c[t]he promotion of social welfare does not include direct or indirect participation or intervention in political campaigns on behalf of or in opposition to any candidate for public office.\u201d  So, some ask \u2013 some curiously, some cynically \u2013 what is it?  Is \u201cpublic welfare\u201d an \u201coperated exclusively\u201d test\u201d or a \u201cprimarily engaged\u201d test?  Does any<\/em> \u201cparticipation \u2026 in political campaigns\u201d (which \u201c[t]he promotion of social welfare does not include\u201d) prevent exclusive<\/em> operation for the promotion of social welfare?  Or is \u201cprimarily\u201d really a mechanical 51 percent test?  Or how about 40 percent if the other two<\/em> activities are only 30 percent each?  And how can such activities be quantified anyway?<\/p>\n\n\n\n

    Apparently only the last few questions will be within the scope of this Priority Guidance Plan project.  Notice that the description of this project in the Priority Guidance Plan does not challenge the difference in wording between the statute and the regulation (as many observers have).  It appears to accept the regulation and seeks only to provide metrics for its application.  Critics will have a field day, and Capital Letters defers to them.  The only purpose here is to show how a familiar tool like the annual Priority Guidance Plan can understandably be infused and shaped by the headlines of the day.  This project, while important, is likely to play only a small role, if any, in calming the larger storm.  The process and personnel issues will continue to dominate.<\/p>\n\n\n\n

    NOMINATION OF A NEW COMMISSIONER OF INTERNAL REVENUE<\/p>\n\n\n\n

    Into this storm the new Commissioner of Internal Revenue must parachute.  Under section 7803(a)(1)(B)<\/a> of the Internal Revenue Code \u2013 not the most discussed Code section at CLE programs \u2013 the Commissioner serves a five-year term that begins on November 13 of every year ending with 7 or 2.  Douglas Shulman\u2019s term ended last November.  The President could have nominated a new Commissioner about ten months ago.  For all we know he tried; it can\u2019t be easy.<\/p>\n\n\n\n

    On August 1, the President announced his intention to nominate John Koskinen.  Famously, because everything any Administration official says about the IRS these days is scrutinized, the President described the nominee as \u201can expert at turning around institutions in need of reform.\u201d  Although he practiced law in the 1960s, the fact that he does not have a tax background has of course been noticed.  But section 7803(a)(1)<\/a> mandates that the appointment of the Commissioner \u201cshall be made from individuals who, among other qualifications, have a demonstrated ability in management\u201d and says nothing specifically about a tax background.  It might be thought that a tax background is assumed, but section 7803(c)(1)(B)(iii)(I)<\/a>, in prescribing the qualifications for the National Taxpayer Advocate, does specify \u201ca background in customer service as well as tax law.\u201d  In fact, since the enactment of the Internal Revenue Service Restructuring and Reform Act of 1998, which was passed after sensational hearings and charges of abuse (imagine that!), no tax professional has served as Commissioner; the last was Peggy Richardson in 1993-97.  (Two ACTEC Fellows have been Commissioners, Larry Gibbs in 1986-89 and Shirley Peterson in 1992-93. Shirley had chaired ACTEC\u2019s Transfer Tax Study Committee in its early days in the 1980s, and Larry went on to be a member of the Board of Regents in the 1990s.)<\/p>\n\n\n\n

    John Koskinen, whom I know and respect, has the temperament and managerial instincts for the job and the times.  He deserves our support and best wishes.  Perhaps mercifully, his \u201cfive-year term\u201d will end in November 2017.<\/p>\n\n\n\n

    Ronald D. Aucutt<\/p>\n\n\n\n

    \u00a9 2013 by Ronald D. Aucutt. All rights reserved<\/p>\n","protected":false},"excerpt":{"rendered":"

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