Strategy Considerations for Global Litigation
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
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
In 2009, each individual had a $3.5 million estate tax exemption. If a married individual had assets over $3.5 million, without careful planning, those assets in excess of $3.5 million would fall subject to a 45% estate tax....more
The IRS released new final estate and gift tax regulations that include guidance on taxpayers seeking so-called “portability” elections to carry over the lifetime exclusion from the first spouse to die to the second spouse. ...more