Once Removed Episode 18: The Reciprocal Trust Doctrine
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
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
April Interest Rates for GRATS, Sales to Defective Grantor Trusts, Intra-Family Loans and Split-Interest Charitable Trusts - The April Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and...more
The April Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.0%. The April applicable federal rate (“AFR”) for use with a sale to a defective grantor trust or intra-family loan...more
On March 20, 2023, Senators Warren, Sanders, Van Hollen, and Whitehouse addressed a letter to Treasury Secretary Yellen in which they urged Yellen “to use [her] existing authority to limit the ultra-wealthy’s abuse of trusts...more
Some folks eagerly await the release of a new album. Others camp outside of big box retailers to get the jump on holiday gifts. There are those who line up at box offices to purchase tickets for a concert that is months away....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
On Friday, July 13, 2018, the U.S. Department of the Treasury (the “Treasury”) and the IRS published Notice 2018-61 (the “Notice”), stating that they plan to issue regulations providing clarification of the effect of § 67(g)...more
On October 13, 2016, Treasury and the IRS issued new final and temporary “anti-inversion” regulations under section 385 of the Internal Revenue Code that could treat certain purchasers of notes issued by securitizations as...more
The Department of the Treasury has released the Treasury Green Book for Fiscal Year 2017, which provides explanations of the President’s budget proposals. One such proposal (remember…these are just proposals, not actual...more
In March, the Department of Treasury issued the administration's 2015 fiscal year revenue proposals for the federal government. Those proposals are described in General Explanations of the Administration's Fiscal Year 2015...more