Many Canadians own US-situs real estate, whether it is in New York, Florida, California or elsewhere in the US. It is often a surprise (or a “trap for the unwary”) to Canadian clients (or for that matter, any non-US client)...more
In a recently-issued Revenue Ruling (Rev Rul 2023-02), the IRS has held that the basis of the assets in an irrevocable grantor trust, where the assets are not included in the grantor’s gross estate for federal estate tax...more
Closely-held businesses come in all shapes and sizes. Some owners own 100% of their businesses. Some have partners. Some have children in the business. Some do not. A common question that a client asks the business and...more
3/3/2021
/ Asset Protection ,
Business Succession ,
Closely Held Businesses ,
Estate Planning ,
Estate Tax ,
Family Businesses ,
Gift Tax ,
Income Taxes ,
Partnerships ,
Succession Planning ,
Surviving Spouse ,
Trusts
Trust and estate planners are still catching their breath from the 2020 year-end and dealing with the wave of gifting transactions that many clients completed. It seems the ink is not dry on those December transactions and...more
Seasoned trusts and estates practitioners know certain truths, such as:
Stuff happens.
Some estate tax disputes should not be litigated, but they are anyway.
Sometimes justice is done....more
In a closely-watched decision, the U.S. Supreme Court unanimously ruled that a beneficiary’s residence within a state alone does not subject a trust to such state’s income tax. In North Carolina Dept. of Revenue v. Kimberley...more
6/26/2019
/ Beneficiaries ,
Due Process ,
Estate Tax ,
Exclusive Control ,
Forum State ,
In-State Beneficiaries ,
Income Taxes ,
Minimum Contacts ,
North Carolina Department of Revenue v The Kimberley Rice Kaestner 1992 Family Trust ,
SCOTUS ,
State Taxes ,
Trust Distributions ,
Trustees ,
Trusts
The New Jersey Tax Court recently released its opinion in Estate of Ruth Oberg, NJ Tax Court, Docket No 000240 (October 24, 2017), upholding the Division of Taxation’s assessment of additional New Jersey estate tax. The case...more
On October 14, 2016, Governor Christie signed into law a transportation funding bill that also included the repeal of the New Jersey Estate Tax. Here is what you need to know: -
The New Jersey Estate Tax repeal will be...more
The IRS has at last issued long-anticipated proposed regulations under Code §2704. We perceive the proposed regulations as an attempt by the IRS to curtail the use of discounts – such as minority interest and lack of...more
Prince was not the first famous person to die without a Will. Others who died intestate include: Abraham Lincoln, Ulysses S. Grant, Howard Hughes, Martin Luther King, Jr., Sonny Bono and Pablo Picasso. Dying intestate is...more
The loss of a loved one is a traumatic event and it can be among the most challenging of times to make important financial decisions. Proactive planning with an attorney and financial planner can significantly lessen the...more
Estate tax exemption increase. Effective April 1, 2014, the New York State estate tax exemption increased to $2,062,500 for New York residents dying between April 1, 2014 and April 1, 2015 and will increase to $3,125,000 on...more
There have been important new developments for New York taxpayers over the past two months, some of which may require your immediate attention. ...more
Congress took the fiscal cliff negotiations over the brink but was finally able to reach a deal resulting in the American Taxpayer Relief Act of 2012 (“2012 Act”). The 2012 Act makes the estate and gift tax laws “permanent,”...more