Advisers focused on private clients commonly overlook planning for the income and estate taxes on income in respect of a decedent
A category of assets known as income in respect of a decedent
(IRD) does not.
Income in respect of a decedent
(IRE)) generally consists of items of gross income a decedent was entitled to at death that, because of the decedent's method of accounting, were not included in the final individual return; see Pegs.
The Service held that the transfer to the trust will not be treated as a sale or disposition of the IRA, nor give rise to income recognition under the Code's rules for income in respect of a decedent
It also discusses cases and rulings on administrative expense deductibility, the qualified terminable interest property (QTIP) election, disclaimers, spousal election rights, charitable remainder trusts (CRTs) and income in respect of a decedent
IRC section 691(a)(5)(iii) contains rules similar to those of section 453B(f) and governs income in respect of a decedent
occurring on cancellation of installment notes.
In Robinson, 69 TC 222 (1977), the Tax Court examined whether to discount the value of installment notes in an estate for future income taxes that the beneficiaries of those notes would pay on the income in respect of a decedent
(IRD) included in future installments.
The owner's death, however, does not extinguish the income tax liability associated with IRA distributions; the distribution is income in respect of a decedent
(IRD) for income tax purposes.
691 nor 1022 provides an adjustment to basis for state death taxes paid on items of income in respect of a decedent
The corporation has no income in respect of a decedent
691(c) income tax deduction for estate tax attributable to items of income in respect of a decedent
(IRD), which are taxable to an estate or beneficiaries, operates in the form of a valuation discount (in lieu of an estate tax reduction).
Items of income in respect of a decedent
(IRD) do not receive a basis step-up and, thus, are potentially subject to both estate and income taxes.