Once Removed Episode 22: Building Flexibility into the Estate Plan
A Primer On Trusts - A Podcast with Janathan Allen
INTRODUCING MALTA SPLIT DOLLAR
What is an Irrevocable Trust?
As part of the Tax Cuts and Jobs Act (TCJA), the estate and gift tax exemption was doubled for tax years 2018-2025. In 2018, the exemption doubled from $5.49 million in 2017 to $11.18 million in 2018, and that amount has been...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
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
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
If you own your principal residence, you may be able to benefit from its build-up in equity, realize current tax breaks and pocket a sizeable tax-exempt gain when you sell it. What’s more, from an estate planning perspective,...more
For some time, promoters have shopped around an arrangement known as a “section 643(b) trust,” known alternatively as a “non-grantor, irrevocable, complex, discretionary, spendthrift trust.” On August 9, 2023, IRS Chief...more
In establishing and funding an irrevocable trust, a common question is who is responsible for the income tax liabilities associated with the trust? Many individuals assume that the trust is a separate and independent...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
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
Key points •On Wednesday, September 15, The House Ways and Means Committee advanced a proposal for a $2.1 trillion tax increase. •The proposal could drastically change the gift and estate tax treatment of new...more
Learn how to convert tax deferred dollars into tax-free dollars using Malta Split Dollar....more
Under the Tax Cuts and Jobs Act, in 2020 each person may transfer up to $11,580,000 without incurring a gift or estate tax. This generous exemption amount will sunset at the end of 2025, which means that in 2026, the...more
The 2020 election is less than a month away and year-end estate planning is already underway for many. Under current law, the estate, gift and GST (generation-skipping transfer) tax exemptions for 2020 are set at $11,580,000...more
We are seeing an increasing number of clients that want to situs trusts in Wyoming due to its favorable trust law and lack of state income tax, although over the last several months clients have also sought the open spaces of...more
Now may be an opportune time to gift assets out of your estate, particularly through an estate planning technique known as the Grantor Retained Annuity Trust (“GRAT“)—a small silver lining of the alarming pandemic and down...more
Major tax reform discussions are ongoing in Washington and Sacramento while everyone at home is busy navigating the pandemic. Many commentators are predicting that budgetary pressures resulting from the COVID-19 stimulus...more
In the wake of COVID-19, we may see significant statutory changes to the federal estate, gift, and generation-skipping transfer tax exemptions. Spousal Lifetime Access Trusts and other planning techniques provide...more
On July 18, 2018, the Minnesota Supreme Court issued its decision in Fielding v. Commissioner, declaring that it was unconstitutional for the state to consider four trusts to be Minnesota “resident trusts” — and tax them...more
In a 4-2 decision, the Minnesota Supreme Court ruled in Fielding v. Commissioner that four trusts lacked sufficient relevant contacts with Minnesota during the applicable tax year to be permissibly taxed, consistent with due...more
Trustees of irrevocable trusts created by Minnesota residents may be impacted by a recent decision of the Minnesota Supreme Court. On July 18, 2018, in Fielding v. Commissioner of Revenue...more
The Tax Cuts and Jobs Act of 2017 (the Act) signed into law by President Trump on December 22, 2017 made sweeping changes that affect individuals, businesses, trusts and estates. This alert focuses on the impact of the Act on...more
Typically, a trust must file a separate income tax return for each calendar year. However, for most grantor trusts, filing a separate tax return is optional. The general rule and the alternative methods of reporting are...more
In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more
October Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The October Section 7520 rate for use with estate planning techniques such as CRTs, CLTs,...more
October Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The October § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more