News & Analysis as of

Transfer Taxes Internal Revenue Code (IRC)

ArentFox Schiff

The Sunset of the Doubled Estate, Gift, and GST Tax Exclusion Amounts After December 31, 2025

ArentFox Schiff on

The TCJA doubled the lifetime exclusion and GST tax exemption. This exclusion amount, adjusted for inflation, is now $13.61 million and is expected to be approximately $13.99 million in 2025. However, in 2026, the amount will...more

Pillsbury Winthrop Shaw Pittman LLP

IRS Issues Proposed Updates to Qualified Domestic Trust Regulations

The proposed regulations update outdated references and information under the current regulations, including references to temporary regulations, IRS officials, offices and addresses. The proposed regulations conform with...more

Rivkin Radler LLP

Transferee Liability for Estate Tax: The Downside of Being a Beneficiary

Rivkin Radler LLP on

Death of a Parent- In the context of a family-owned business, it is often the case that the matriarch or patriarch of the family is also the chief executive of the business. They may have founded the business, or they may...more

Proskauer Rose LLP

Wealth Management Update - April 2023

Proskauer Rose LLP on

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

Williams Mullen

Estate Planning Adjustments for Tax Year 2019

Williams Mullen on

Many estate planning provisions of the Internal Revenue Code contain brackets, exemptions, exclusions, deductions, or other figures that the Internal Revenue Service (IRS) adjusts annually for inflation. Recently, the IRS...more

Jones Day

House of Representatives Releases First Draft of Tax Reform Bill

Jones Day on

The Situation: On November 2, 2017, the House Ways and Means Committee released its first draft of much-anticipated comprehensive U.S. tax reform legislation as the "Tax Cuts and Jobs Act." Chairman Brady’s markup of the bill...more

McGuireWoods LLP

Estate Tax Changes Past, Present and Future

McGuireWoods LLP on

I. INTRODUCTION - This outline is a selective and evolving review of the history of the modern federal estate tax. It originated during the attempts to repeal the estate tax in President Clinton’s second term and...more

Adler Pollock & Sheehan P.C.

The Future Of Proposed IRS § 2704 Modifications Is Uncertain

Proposed changes to Internal Revenue Code (IRC) § 2704, which would impact the valuation of transfers of family business interests at death, come at an interesting time politically given the Trump Administration’s desire to...more

Dickinson Wright

KNOWN UNKNOWNS about Federal Tax Laws and Regulations

Dickinson Wright on

The new administration in Washington, supported by Republican majorities in Congress, has pledged substantial changes to federal tax laws and regulations. One change may - or may not - be the complete elimination of federal...more

Perkins Coie

What Proposed Tax Plans by Trump Administration and House Republicans Mean for Personal Planning

Perkins Coie on

The election of Donald Trump and Republican majorities in U.S. Congress make the future of the federal transfer tax system (gift, estate and generation-skipping transfer (GST) taxes) uncertain. President-elect Trump and...more

Proskauer Rose LLP

Valuation Discounts for Transfers of Interests in Family Entities May Be Severely Curtailed – You May Want To Act Now

Proskauer Rose LLP on

On August 2, 2016, the Treasury Department and the Internal Revenue Service (the "IRS") issued proposed regulations under section 2704 (the "Proposed Regulations") of the Internal Revenue Code of 1986, as amended (the...more

Pierce Atwood LLP

New Hampshire Enacts Business-Friendly Tax Changes

Pierce Atwood LLP on

Three business-friendly tax bills have become law in New Hampshire. Each bill will result in tax reductions for those able to take advantage of them. The New Hampshire Business Profits Tax generally “piggybacks” on the...more

McDermott Will & Emery

IRS Issues Updated Notice Regarding Safe Harbor for Transfers of Property to Regulated Public Utilities by Electricity Generators

McDermott Will & Emery on

In Depth - On June 10, 2016, the Internal Revenue Service (IRS) issued Notice 2016-36 (the Notice), updating the safe harbor (Safe Harbor) regarding transfers of property from an electricity generator to a regulated...more

Troutman Pepper

The Time to Transfer Entity Interests Is Now - Trust and Estates Update Vol. 2015, Issue 1

Troutman Pepper on

Upcoming IRS regulations may significantly limit and reduce planning opportunities to transfer minority interests in closely held entities to family members and increase the transfer tax cost associated with moving such...more

Miller & Martin PLLC

New Section 336(e) Election Provides Additional Flexibility in Taxation of Stock Transactions

Miller & Martin PLLC on

On May 15, 2013, the Department of the Treasury issued final regulations regarding a new election now permitted under Section 336(e) of the Internal Revenue Code that allows sellers to elect to treat transactions structured...more

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