Once Removed Episode 18: The Reciprocal Trust Doctrine
On this episode of “Splitting Heirs,” Warren K. Racusin welcomes back Sharon L. Klein, President of Family Wealth for the Eastern US Region of Wilmington Trust Company and member of the Estate Planning Hall of Fame, to...more
September 2024 AFRs and 7520 Rate - The September 2024 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 4.8%, a decrease from the August 2024 rate of 5.2%. The September...more
El 18 de abril de 2024, FinCEN actualizó las preguntas frecuentes (“FAQs) que abordan los fideicomisos y el CTA (“Corporate Transparency Act”). Los fideicomisos son vehículos que pueden ayudar a preservar patrimonios y la...more
On April 18, 2024, FinCEN updated FAQs that address Trusts and the CTA (Corporate Transparency Act). Trusts are vehicles that can assist in the preservation of wealth and property for future generations, protect assets, or...more
Financial markets, political moods, and the world-at-large can take us on a roller coaster ride of ups and downs. But savvy investors (and their estate planning counsel) know that – in the end – neither the bears nor bulls...more
The Tax Cuts and Jobs Act of 2017 provided major changes to the Internal Revenue Code, specifically doubling the federal estate, gift, and generation-skipping transfer (GST) tax exemption (collectively, the exemption) from...more
This CLE/CPE webinar will provide estate planners insight on recently issued IRS guidance regarding basis adjustments for irrevocable grantor trusts. The panelist will discuss key items and challenges stemming from Revenue...more
This podcast often discusses the elements of a trust, and how to grant access, control and flexibility to beneficiaries and trustees. But for tax and other purposes, the donor typically cannot retain those kinds of powers. ...more
Earlier this week the White House released its Fiscal Year 2025 Budget. Of course, the federal government has not yet adopted a budget for the Fiscal Year 2024 even as we approach that year’s halfway mark. But I digress. The...more
A Beneficiary Intentionally Defective Irrevocable Trust (BIDIT) provides a unique planning opportunity because it allows a beneficiary to continue to benefit from his or her own assets while maintaining some level of control...more
Thanks to a generous federal gift and estate tax exemption amount ($13.61 million for 2024), only the wealthiest of families are exposed to estate tax liability. For many, this means that estate planning now has a stronger...more
Trusts are described in multiple ways, including: living or testamentary, revocable or irrevocable and grantor or non-grantor. These terms are not always mutually exclusive. A trust can be living, revocable and a grantor...more
A trust structure, commonly used for estate planning, can be problematic in certain civil law jurisdictions, such as those in many European countries. Recent acts enacted in Wyoming and New Hampshire allow for the...more
Starting January 1, 2025, the individual who is the grantor of a trust that qualifies as a grantor trust under Sections 671 through 679 of the Internal Revenue Code will himself or herself be subject to Pennsylvania Personal...more
Until recently, there was a fair amount of comfort amongst practitioners that, when structured correctly, utilizing a tax reimbursement clause for a grantor trust did not produce any negative U.S. gift or estate tax results....more
January 2024 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The January applicable federal rate (“AFR”) for use with a sale to a defective grantor...more
On November 24, 2023, the IRS released PLR 202347001, ruling that certificates issued from an “exchange trust” qualify as stripped bonds or stripped coupons within the meaning of Code Section 1286. The taxpayer in the...more
The Corporate Transparency Act (the “CTA”), a set of new regulations being implemented by the Financial Crimes Enforcement Network (“FinCEN”), requires entities newly formed or registered to do business in the United States...more
Although the IRS is now on high alert for wealthy individuals, new and existing planning opportunities are available, such as tax-free gifts and other advantageous planning. Wealthy individuals and families should take...more
On September 27, 2023, H.R. 5761, the “Opportunity Zones Transparency, Extension and Improvement Act” was introduced as bipartisan legislation in the US House of Representatives. Among other things, the proposed...more
The August 2023 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5%, an increase from the July 2023 rate of 4.6%. The August applicable federal rate (“AFR”) for use with a sale...more
Earlier this week, California Gov. Gavin Newsom signed into law a retroactive tax on so-called “INGs” — Incomplete Gift Non-Grantor Trusts. Note that the law, which is retroactive to Jan. 1, 2023, has some limitations in...more
Grantor trusts allow for tax deductions on income generated by trust assets whereas non-grantor trusts do not allow for these deductions. It is crucial for people to carefully decide which type of trust is best for their...more
June 2023 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split-Interest Charitable Trusts - The June Section 7520 rate for use in estate planning techniques such as CRTs, CLTs, QPRTs...more
The Spousal Lifetime Access Trust, or SLAT, has become one of the most popular estate planning strategies employed by married couples. It is an irrevocable trust created by one spouse (the “grantor”) for the benefit of the...more