News & Analysis as of

Gift Tax

QDOT-ting I's and Crossing T's: Estate Tax Planning for Non-United States Citizen Spouses

by Ward and Smith, P.A. on

Individual and corporate citizens from countries around the world have moved to North Carolina and contributed materially to our state's economic, educational, and cultural growth. Foreign direct investment ("FDI") in North...more

Foreign Investment in U.S. Real Property: Gift And Estate Tax Considerations

by Farrell Fritz, P.C. on

Last week, we reviewed the various U.S. federal income tax consequences that may be visited upon a foreign person who owns and operates U.S. real property (“USRP”). Today we will consider the U.S. federal gift and estate tax...more

30 Rock, Oysters, and Generation-Skipping Transfer Tax

by Bryan Cave on

Billionaire David Rockefeller, the grandson of John D. Rockefeller, passed away recently at the age of 101. In 2017, Forbes estimated that his fortune, investments in real estate, share of family trusts, and other holdings...more

IRS Recognizes Retroactive Validity of GRAT Based Upon Court Reformation

by Genova Burns LLC on

The IRS recently examined whether a Grantor Retained Annuity Trust (hereinafter “GRAT”) could be held valid despite the fact that it omitted certain key language. In a GRAT, the Grantor transfers property into the irrevocable...more

Update on 2704 Proposed Regulations and Impact on 2016 Gift Tax Reporting

by Dickinson Wright on

Following the December 1, 2016 public hearing, the IRS reportedly began working on revisions to and clarifications of the new 2704 proposed regulations. While the uproar from the estate planning and accounting communities...more

Do you have to file a gift tax return (Form 709) for 2016?

by Dickinson Wright on

If you made a gift to one individual in excess of $14,000 during 2016 (or $28,000 if you are married and you and your spouse agreed to "gift split"), then you will likely be required to file a gift tax return....more

Properly structured foreign gifts of real property property can be estate and gift tax free

by Sanford Millar on

The investment in U.S. real property by Non-residents can be structured to minimize estate and gift taxes. The key is to structure the investment through a limited liability company, limited partnership or corporation so...more

IRS Limiting GST Private Letter Rulings and Presubmission Conferences

by Charles (Chuck) Rubin on

At a recent Federal Bar Association Tax Law Conference, an IRS Chief Counsel branch chief advised that due to budget cuts: a. The IRS has temporarily suspended issuing private letter rulings regarding modifications to...more

Estate Tax Changes Past, Present and Future

by McGuireWoods LLP on

I. INTRODUCTION - This outline is a selective and evolving review of the history of the modern federal estate tax. It originated during the attempts to repeal the estate tax in President Clinton’s second term and...more

Potential Repeal of the ‘Death’ Tax

by McNair Law Firm, P.A. on

Assuming you have not been living under a rock for the last two years you have heard of Donald J. Trump, now President Trump, speak about the need to repeal the so-called “Death tax”. In addition, you are likely aware that...more

Estate Tax Reform Predicted for 2017

by Ward and Smith, P.A. on

A key goal for those of us who practice with Ward and Smith is to inform our clients and future clients of potential developments that may impact them.  With respect to Trust and Estate Law, the potential for repeal of the...more

KNOWN UNKNOWNS about Federal Tax Laws and Regulations

by Dickinson Wright on

The new administration in Washington, supported by Republican majorities in Congress, has pledged substantial changes to federal tax laws and regulations. One change may - or may not - be the complete elimination of federal...more

"Income, Wealth Transfer Tax Changes Likely Under New Administration"

Comprehensive federal tax reform likely will be a top priority for the Trump administration and Republicans in Congress in the first half of 2017. Although there are differences between their proposals, President Donald Trump...more

Client Alert: Estate and Gift Tax Limits Announced for 2017

by Fraser Trebilcock on

The IRS has issued the estate and gift tax limits for 2017 (Rev. Proc. 2016-55). For an estate of a person dying in 2017, the basic exclusion amount is $5,490,000 for determining the credit against federal estate tax. This...more

Wealth Management Update - February 2017

by Proskauer Rose LLP on

February Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The February § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more

IRS Permits Trust Division Without Adverse Federal Tax Consequences

by Charles (Chuck) Rubin on

In Private Letter Rulings 201702005 and 201702006, the IRS favorably ruled on federal tax consequences of a proposed trust division. But for a minor change in facts, the two rulings are identical, so we will focus only on...more

Federal Gift, Estate Tax and Generation-Skipping Transfer Tax Exemptions & the Gift Tax Annual Exclusion Amount Are Subject to...

by Dickinson Wright on

The exemptions were increased in 2017 from $5,450,000 to $5,490,000, and the annual exclusion remains the same at $14,000 per donee. These rules mean the following...more

Quarterly Investment Update - 4th Quarter 2016

by Perkins Coie on

ECONOMIC REVIEW AND OUTLOOK - In this past year we were reminded again to expect the unexpected: The well-established political classes in the U.K., the U.S. and Italy learned that democracy was their Achilles’ heel, and...more

Estate Tax Changes Past, Present and Future

by McGuireWoods LLP on

INTRODUCTION - This outline is a selective and evolving review of the history of the modern federal estate tax. It originated during the attempts to repeal the estate tax in President Clinton’s second term and...more

2017 California Estate and Tax Planning Newsletter

by Blank Rome LLP on

Blank Rome’s annual estate and tax planning newsletter addresses estate planning concepts and techniques that should be considered in 2017 by our clients and friends. Transfer Taxes. The major changes made in 2010 in the...more

A Reprieve from Proposed Regulations Related to Valuation of Family Businesses?

In December, we posted a blog discussing a much anticipated hearing held on the Treasury Department’s issuance of proposed regulations under Section 2704 of the Internal Revenue Code (sometimes referred to as the 2704...more

2017 – New Year, New Adjusted Lifetime Federal Estate and Gift Tax Exempt Amount

by McNair Law Firm, P.A. on

The annual federal exemption amount for the estate and gift tax has been adjusted to $5,490,000.00 per individual for 2017. This means a married couple will have a combined $10,980,000.00 in 2017. The $5,490,000.00...more

Treasury Department Unofficial Statements on Proposed Section 2704 Regulations

by Charles (Chuck) Rubin on

There is a lot of uncertainty whether the Section 2704 proposed regulations will ever be finalized, either due to policy to be set by President-elect Trump, and/or Congressional efforts to block those regulations....more

2016 Year-End Tax Update: Okay, Now What?

by Cozen O'Connor on

In last year’s materials, loosely styled “Make America Great Again!,” we ruminated upon (and also thought about) what role, if any, federal income taxes might play in helping to make America great again, once the interminable...more

Trusts and Estates Group News: 2017 Federal Inflation Adjustments

by Murtha Cullina on

Each year, certain federal estate, gift and generation-skipping transfer (GST) tax figures are subject to inflation adjustments. Effective January 1, 2017, the annual exclusion amount for gifts per donee remains at...more

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