Strategy Considerations for Global Litigation
In the technology world, portability has become increasingly important as people become more mobile and reliant on a variety of devices to access and use information. Portability allows individuals to work remotely or while...more
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
Every U.S. citizen may gift, during life or at death, assets to his or her children free of federal estate or gift tax up to an aggregate amount – frequently called the “exemption amount.” The exemption amount in 2021 is...more
The Tax Cuts and Jobs Act provides greater flexibility in estate planning for many taxpayers. So, no more estate tax worries for most people, right? Not so fast. For residents of some states, state estate or inheritance taxes...more
Somewhat lost in the clamor of the tax changes enacted by the Tax Cuts and Jobs Act is the fact that the new law preserves the “portability” provision for married couples. Portability allows an estate to elect to permit the...more
On December 22, 2017, President Trump enacted the Tax Cuts and Jobs Act, (“TCJA”) ushering in significant changes to the federal estate, gift and generation-skipping transfer tax laws. Through December 31, 2017, the federal...more
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
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
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
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
The U.S. Supreme Court’s ruling in United States v. Windsor will forever change many facets of the lives of same-sex couples....more
The American Taxpayer Relief Act of 2012 (the “2012 Act”) had a profound impact on the transfer tax system. I will briefly describe that system and then, by way of background, set the stage for these changes by summarizing...more
It has often been said that the only things in life that are certain are death and taxes. Until two weeks ago, the “taxes” part of that phrase was not so certain. However, on January 2, 2013 President Obama signed the...more
Congress has averted the so-called fiscal cliff by passing the "American Taxpayer Relief Act of 2012" (the "Act") on January 1, 2013, which President Obama signed into law the following day. The good news is we finally have...more