Estate, Trust, & Gift  Tax

Situation: An individual faced an IRS balance exceeding $300,000 after an IRA distribution had been incorrectly treated as an early withdrawal.

Solution: Tronconi Segarra & Associates reviewed the transaction, prepared supporting documentation, and represented the taxpayer in resolving the matter with the IRS.

Impact: The client’s liability was reduced from more than $300,000 to only a few hundred dollars.

Situation: A business owner with companies in Canada and the United States planned to move permanently to the United States.

Solution: Our team partnered with the client’s Canadian advisor to restructure entity holdings for U.S. residency and address Canadian exit tax within the business owner’s succession plan.

Impact: The client deferred approximately $120,000 in exit tax and advanced planning for U.S. estate tax considerations.

Situation: An incorrect foreign trust filing prevented the IRS from processing a refund of nearly $1 million for almost three years.

Solution: Our team identified the filing error, prepared the correct filing and supporting documentation, and began addressing account verification and withholding issues with the IRS.

Impact: The client gained a coordinated approach to resolving the filing problems and pursuing the refund. The IRS resolution remains in progress.

Situation: The IRS questioned the foreign withholding reported on an individual’s tax return, putting a substantial refund at risk.

Solution: Our team reviewed transaction records, assembled supporting evidence, and represented the taxpayer in discussions with the IRS.

Impact: We substantiated the withholding and helped the client obtain a refund exceeding $600,000.

Situation: An estate planning client had incomplete foreign corporation filings and an unaddressed  transition tax obligation going back several years, creating extended tax and penalty exposure.

Solution: Our team completed the required forms and prepared the transition tax calculations and disclosures.

Impact: Our expertise reduced the client’s current tax liability by more than $100,000 and avoided potential penalties exceeding $300,000.

Situation: A client had concerns about filings for a trust established by her parents, despite relying on another accounting firm to handle trust matters for several years.

Solution: Our Trusts & Estates team reviewed the filings, identified and corrected multiple issues, and brought the reporting up to date.

Impact: The client gained greater confidence in the trust’s administration, sharing, “This is the first time I’ve felt good about everything.”

Situation: A client facing a significant New York State estate tax issue needed immediate planning because of declining health.

Solution: Our Trusts & Estates team implemented charitable giving strategies before our client’s passing, then researched and evaluated tax positions during estate administration.

Impact: The combined planning and analysis helped bring the estate below New York’s estate tax cliff and substantially reduced the estate’s potential tax burden.