Once Removed Episode 18: The Reciprocal Trust Doctrine
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
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
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
May 2023 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split-Interest Charitable Trusts - The May Section 7520 rate for use in estate planning techniques such as CRTs, CLTs, QPRTs and...more
Leveraging QPRTs in a High Interest Rate Environment - A Qualified Personal Residence Trust, or “QPRT” is a planning strategy specifically authorized in the Internal Revenue Code that allows an individual to remove a...more
“Déjà vu All Over Again”- The White House last week released the President’s Budget for the Fiscal Year 2023. The Budget is ambitious, but its “investments,” we are told, “are more than paid for with tax reforms focused on...more
Under the Internal Revenue Code’s “grantor trust” rules, the grantor of a trust may be treated as the “owner” of all or part of the trust. As such, the grantor is taxed on the trust’s income and reports its deductions...more
You likely are aware, from the news and our prior communications, that Congress currently is considering proposals that may have a significant impact on many estate plans. Although we still cannot be certain which, if any, of...more
In the recent case of Heiting v. United States, the Seventh Circuit Court of Appeals denied the taxpayer’s claim-of-right deduction pursuant to Internal Revenue Code section 1341. The case stemmed from the taxpayer’s attempt...more
Certain revenue-raising proposals that would have affected the transfer tax regime and estate planning of high-net-worth individuals and trusts, which were included in the prior proposed bill in the House of Representatives,...more
What You Should Know •The House Ways and Means Committee has approved the tax provisions of President Biden’s Build Back Better Act, a significant first step towards passage. •If passed as drafted, the proposed...more
The U.S. House of Representatives bill released last month proposes several changes to the current rules governing trusts where the grantor pays the income tax, but the value of which is not included in the grantor’s estate...more
Last month, the House Ways & Means Committee (the "Committee") approved draft legislation (the “Legislation”) as part of Congress' ongoing $3.5 trillion budget reconciliation process. The Legislation includes significant tax...more
Act Now Before the Window of Opportunity Closes - By now you have probably heard that the House Ways and Means Committee introduced legislation a few weeks ago (see Let the Estate Tax Planning Games Begin - But Where Will...more
Plan focuses on eliminating certain available estate planning opportunities and increasing rates for corporations and high net worth individuals. The proposed tax plan from House Ways and Means Committee seeks to eliminate...more
On September 10, 2021, the U.S. House Committee on Ways and Means released a draft of proposed legislation that, if enacted into law, would reduce the estate tax exemption and significantly limit the effectiveness of certain...more
The U.S. House Committee on Ways and Means’ tax proposals would significantly impact estate planning for high net worth individuals if enacted. Gift, estate and GST exemption amounts would be decreased; grantor trusts would...more
In this second blog post on the House Ways and Means Tax proposals, we address the proposed changes that will affect the taxation of trusts, estates, and retirement plans. As we discussed, on September 13, 2021, the...more
What you need to know: On September 13, 2021, the House Ways and Means Committee released its proposed tax plan to fund President Biden’s $3.5 trillion “Build Back Better” social and economic spending package. If enacted as...more
Where Are We? Have you seen the Triumvirate of late? No, not Julius, Pompey, and Crassus. I’m referring to more contemporary political figures, whose names and exploits are not likely to appear in volumes that will be...more
Last week the House Ways and Means Committee released a draft of proposed tax law changes to include in a reconciliation bill. While it is uncertain whether any of these proposals will be adopted – and if so in what form –...more
As many people are aware, Congress is considering changes to the federal tax code to support President Biden’s Build Back Better spending plan. As of this writing, on September 22, 2021, no bill has been enacted....more
It is said that two things are certain in life: death and taxes. True, but incomplete. What is missing from this short list is a third inevitable occurrence – tax law changes. We now have a new and pressing series of proposed...more