Monthly Archives: March 2012

It appears that Sonnabend’s heirs sold off works by Jeff Koons, Roy Lichtenstein, Andy Warhol and Cy Twombly to pay estate taxes of $331 million to Uncle Sam and $140 million to New York State.

But they couldn’t even consider selling what might have been the most famous piece in her collection — “Canyon” by Robert Rauschenberg— because the collage contains a stuffed bald eagle and selling it would be a criminal offense, punishable by a year in federal pen.

Given that restriction, the Sonnabend estate tax return (and three different appraisers the estate hired) valued the work at $0. The IRS says it is worth $65 million and is demanding an additional $29 million in tax and an $11.7 million “gross valuation misstatement” penalty from the estate.

To read more go to:

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The Statistics of Income (SOI) Division produces the SOI Bulletin on a quarterly basis.  Articles included in the publication provide the most recent data available from various tax and information returns filed by U.S. taxpayers. This issue of the SOI Bulletin also includes articles on the following:

• Individual income tax rates and shares. Taxpayers filed 140.5 million returns for tax year 2009. Of those, nearly 82 million (or 58 percent) were taxable, which means that, at the return level, the taxpayer reported total income tax greater than zero. Adjusted gross income (AGI) reported on taxable returns was almost $6.8 trillion, while total income tax was $866 billion.
• Split-interest trusts. Charitable remainder trusts, charitable lead trusts and pooled income funds reported $8 billion in gross income and $121.2 billion in end-of-year assets for filing year 2010.
• Domestic private foundations. For tax year 2008, domestic private foundations reported $526.5 billion in total assets and $49.7 billion in total revenue.  These foundations distributed $42.8 billion in contributions, gifts and grants to the charitable sector.     
• Unrelated business income tax returns. For tax year 2008, tax-exempt organizations filed more than 42,000 unrelated business income tax returns and reported $10.3 billion in gross unrelated business income.  
• Personal wealth. In 2007, an estimated 2.3 million U.S. adults had gross assets of $2 million or more, holding more than $12 trillion in combined net worth. The study used information reported on federal estate tax returns.
• Projections of federal tax return filings. The IRS expects that over 239 million tax returns will be filed during calendar year 2012, of which more than 145 million will be from individuals.

The Statistics of Income Bulletin is available for download at IRS.gov/taxstats. Printed copies of the Statistics of Income Bulletin are available from the Superintendent of Documents, U.S. Government Printing Office, P.O. Box 371954, Pittsburgh, PA 15250-7954. The annual subscription rate is $53 ($74.20 foreign), single issues cost $39 ($48.75 foreign).

In addition, the government will be working to “operationalize” government-to-government information sharing agreements under FATCA, she said at the USA Branch of the International Fiscal Association conference.

The United States, France, Germany, Italy, Spain, and the United Kingdom jointly announced they were working toward such agreements Feb. 8, the same day the Internal Revenue Service issued nearly 400 pages of rules that individual banks could use to report U.S.-owned accounts to IRS.
Corwin stressed the government-to-government agreements are not exceptions, but an alternative approach, to FATCA.

She said the United States is currently in discussions with many other jurisdictions on a similar approach.