News & Analysis as of

Internal Revenue Service Portability

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Rivkin Radler LLP

Plan Now for Sunsetting Estate & Gift Tax Exemption

Rivkin Radler LLP on

As we’ve previously discussed, portability is an important feature of an estate plan. Portability allows the surviving spouse to die to “save” any of their predeceased spouse’s unused federal estate and gift exemption amount....more

Cole Schotz

2022/2023 Estate and Gift Tax Update

Cole Schotz on

The IRS has announced the official estate and gift exclusion amounts for 2023. For an estate of any decedent dying during calendar year 2023, the applicable exclusion is increased from $12.06 million to $12.92...more

Lasher Holzapfel Sperry & Ebberson PLLC

It is Now Easier and Less Expensive to File a Late Portability Election via Form 706

On July 8, 2022, the IRS issued Rev. Proc. 2022-32 that simplified the method for obtaining late relief for failure to timely make an estate tax portability election and extending the time for filing portability returns from...more

Cole Schotz

Newly Enhanced Estate Tax Portability Relief under Revenue Procedure 2022-32

Cole Schotz on

Effective July 8, 2022, the IRS issued Revenue Procedure 2022-32 to supersede Revenue Procedure 2017-34 and now allow for a late estate tax exemption portability election to be made up to five (5) years from a deceased...more

Tucker Arensberg, P.C.

IRS Extends Deadline to File Estate Tax Returns for Portability

On July 8, 2022, the IRS issued Revenue Procedure 2022-32, which provides a simplified method for taxpayers to obtain an extension of time to make a portability election of a deceased spouse’s unused exclusion amount (“DSUE”)...more

Roetzel & Andress

IRS Extends Portability Election

Roetzel & Andress on

The Internal Revenue Service recently issued Rev. Proc. 2022-32 which provides that estates may elect “portability” of a deceased spouse’s unused exclusion (DSUE) up to five years after the decedent’s date of death. ...more

Proskauer Rose LLP

Personal Planning Strategies - July 2022

Proskauer Rose LLP on

With Recent Court Decision, Out-of-State Owners of New York Houses Can Breathe Easier - A recent New York appellate court ruling has major implications for individuals who own a house in New York State but do not consider...more

Dickinson Wright

Estate Tax Portability – Not So Fast My Friend

Dickinson Wright on

Many of you have heard of the new Federal estate tax “portability” rule that allows a surviving spouse to effectively inherit any unused federal estate tax exemption of a predeceased spouse. An individual can only use the...more

Genova Burns LLC

Making Use of a Deceased Spouse’s Unused Estate Tax Exemption Simplified

Genova Burns LLC on

The election for married couples to elect portability of the Federal Estate Tax Exemption was introduced in late 2010 when the Tax Relief Unemployment Insurance Reauthorization and Job Creation Act (“TRUIRJCA”) was signed...more

BCLP

IRS Grants Taxpayers Two-Year Window to File Portability Election

BCLP on

In a long-awaited move, the IRS announced recently that taxpayers will now have at least two years to file an estate tax return to elect portability of a decedent’s unused estate tax exemption to the decedent’s surviving...more

Dickinson Wright

IRS issues Rev. Proc. 2017-34 to Extend Time to Make Portability Election

Dickinson Wright on

For individuals dying after December 31, 2010, Section 2010(c) of the Internal Revenue Code provides that the unused estate tax exemption of the first deceased spouse is “portable” between spouses at death. Under this law, a...more

Williams Mullen

Estate Administration Update: A Simplified Procedure for the Portability Election

Williams Mullen on

Recently, the IRS issued Revenue Procedure 2017-34 (the “Revenue Procedure”), providing a simplified process for certain estates requiring an extension of time to make a portability election under § 2010(c)(5)(A) of the...more

Cole Schotz

IRS Simplifies Ability To Obtain Late Portability Election Relief

Cole Schotz on

On June 9, 2017, the Internal Revenue Service issued Revenue Procedure 2017-34, which is effective immediately and provides a simplified method to obtain permission for an extension of time under Reg. 301.9100-3 to file Form...more

BCLP

Court Orders Administrator To Elect Portability

BCLP on

When the IRS enacted the portability election provisions in 2011, which allowed estates of married taxpayers to pass along the unused part of their estate and gift tax exclusion amount to their surviving spouse, it remarked...more

Jackson Walker

Employee Benefits Legislation Proposed (But Not Passed) by the Obama Administration

Jackson Walker on

In February of 2015, the Department of Treasury issued a reported entitled “General Explanation of the Administration’s Fiscal Year 2016 Revenue Proposals” (the “General Explanation”). The General Explanation is several...more

Proskauer Rose LLP

Wealth Management Update - December 2016

Proskauer Rose LLP on

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

Proskauer Rose LLP

Personal Planning Strategies - December 2016

Proskauer Rose LLP on

2017 Estate, Gift and GST Tax Update: What This Means for Your Current Will, Revocable Trust and Estate Plan - As we previously reported, the American Taxpayer Relief Act of 2012 (the "Act") made the following permanent:...more

Katten Muchin Rosenman LLP

2016 Year-End Estate Planning Advisory

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

Dorsey & Whitney LLP

U.S. Tax Implications of Offshore Migration of Intellectual Property

Dorsey & Whitney LLP on

Challenges of Transferring IP Offshore - What constitutes intellectual property (“IP”) has long been a contested issue in tax practice, but generally includes intangible assets as wide-ranging as patents, copyrights,...more

Proskauer Rose LLP

Wealth Management Update - August 2015

Proskauer Rose LLP on

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

Holland & Knight LLP

Regulatory Update: Final Regulations on Portability of the DSUE

Holland & Knight LLP on

Portability of the deceased spousal unused exclusion (DSUE) amount between spouses was first introduced by Congress in December 2010, applicable to estates of married decedents dying on or after Jan. 1, 2011. Although...more

Jackson Walker

IRS Grants Extension of Time to Take Advantage of Portability Election

Jackson Walker on

The IRS has provided relief for persons who missed the opportunity to make a "portability election." To understand the importance of the relief, a review of the basics is in order....more

Ogletree, Deakins, Nash, Smoak & Stewart,...

The Waiting is the Hardest Part: Final Regulations on the PPACA’s 90-Day Waiting Period Released

On February 24, 2014, the Internal Revenue Service (IRS), the Employee Benefits Security Administration (EBSA) of the U.S. Department of Labor (DOL), and the U.S. Department of Health and Human Services (HHS) jointly released...more

McNees Wallace & Nurick LLC

Marriage and Taxes in 2013

Two significant events in 2013 underscored the nexus of marriage and taxes that make it possible for many couples to radically simplify their estate planning. ...more

24 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide