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Estate Planning › Internal Revenue Service

Estate Planning is a process where individuals prepare or plan for the settlement of their personal affairs in the event of incapacitation or death. Estate plans typically include provisions relating to the... more +
Estate Planning is a process where individuals prepare or plan for the settlement of their personal affairs in the event of incapacitation or death. Estate plans typically include provisions relating to the disposition of assets, guardianship of minor children, and appointment of representatives to make medical and financial decisions. Effective estate planning can decrease tax liability and facilitate the probate process.  less -
Proskauer Rose LLP

Wealth Management Update - September 2024 - 2

Proskauer Rose LLP on

September 2024 AFRs and 7520 Rate - The September 2024 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 4.8%, a decrease from the August 2024 rate of 5.2%. The September...more

Proskauer Rose LLP

Wealth Management Update - September 2024

Proskauer Rose LLP on

The September 2024 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 4.8%, a decrease from the August 2024 rate of 5.2%. The September applicable federal rate (“AFR”) for use...more

BakerHostetler

[Podcast] Estate and Tax Planning for Globally Mobile Clients: Purchasing U.S. Real Estate by Non-U.S. Persons

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Non-Americans who wish to purchase U.S. real estate should be aware of the tax consequences of owning real estate here. George McCormick discusses these tax issues and steps to minimize their impact....more

Allen Barron, Inc.

Tax and Estate Planning for Small Business Owners and S Corporations with No Employees

Allen Barron, Inc. on

Many small business owners mistakenly believe business succession planning and estate planning is for those with substantial wealth. This is simply a myth which does not reflect the nature of business or home ownership....more

Kilpatrick

Estate Planning Considerations Post Connelly v. United States

Kilpatrick on

On June 6, 2024, the Supreme Court of the United States issued a unanimous decision in Connelly v. United States and found that life-insurance proceeds payable to a closely held business for the purpose of funding a share...more

Husch Blackwell LLP

Unanimous Supreme Court Determines Company-Owned Life Insurance Increases Fair Market Value

Husch Blackwell LLP on

On June 6, 2024, the Supreme Court held 9-to-0 in Connelly v. United States that company-owned life insurance increases the company’s fair market value for estate tax purposes, and the company’s obligation to redeem a...more

Venable LLP

“Don’t Let the Sun Go Down on Me” - Plan Ahead for the Sunset of Federal Estate and Gift Tax Exemptions at the End of 2025

Venable LLP on

The Tax Cuts and Jobs Act of 2017 (TCJA) enacted significant changes in the federal estate and gift tax laws commencing in 2018. One of the most notable changes was that the TCJA doubled the federal lifetime gift tax...more

Levenfeld Pearlstein, LLC

Redemption Agreements and Life Insurance Proceeds: What the SCOTUS Decision in Connelly Means for Closely Held Businesses

Levenfeld Pearlstein, LLC on

Many closely held businesses have shareholder buy/sell redemption agreements. These agreements are critical to maintaining business continuity when a key shareholder exits the company. When the redemption agreement is...more

BakerHostetler

[Podcast] Estate and Tax Planning for Globally Mobile Clients: Estate and trust planning by non-Americans for American family...

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Non-Americans who undertake estate and trust planning for their American citizen or resident family members should be aware of the unique tax issues that face Americans and consider these issues when doing their planning....more

Pierce Atwood LLP

Sunset and Cloudy Skies on Horizon for Federal Estate Taxation

Pierce Atwood LLP on

Estate planning and wealth transfer professionals have their eyes on the sky as the future of federal estate taxation grows increasingly nebulous. Background - The federal gift and estate tax exemption is the amount...more

Kohrman Jackson & Krantz LLP

Navigating Section 1014 and the TCJA: A Deep Dive into the IRS Ruling on Basis Adjustments

Kohrman Jackson & Krantz LLP on

Understanding the nuances of the Internal Revenue Code (I.R.C.) is crucial for effective estate planning and tax strategy. For example, estate planners must be familiar with the tax basis adjustment provisions in 26 U.S.C. §...more

Tucker Arensberg, P.C.

Business Owner's Guide: Use of Life Insurance for Buyouts

Tucker Arensberg, P.C. on

It is typical to have provisions in the governing documents for your company which contemplate the death and buyout of the owners. Most often, those buyout obligations are funded by the purchase of a life insurance policy on...more

BakerHostetler

[Podcast] Estate and Tax Planning for Globally Mobile Clients: Pre-immigration Planning for Moving to the United States

BakerHostetler on

Individuals considering moving to the United States should be aware of the tax consequences of becoming a U.S. resident and take advantage of tax planning opportunities before moving here. George McCormick discusses these...more

Holland & Knight LLP

Maximize Your Legacy: Take Advantage of the High Estate and Gift Tax Exemption Sunset

Holland & Knight LLP on

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

Blank Rome LLP

Updated Reporting Requirements for Foreign Gifts and Foreign Trusts

Blank Rome LLP on

Proposed Treasury Regulations (the “Proposed Regulations”) have recently been issued to update and clarify existing reporting obligations for U.S. persons who receive gifts from abroad or who are owners or beneficiaries of...more

Miles & Stockbridge P.C.

Supreme Court Case Adversely Impacts Parties to Buy-Sell Arrangements

Miles & Stockbridge P.C. on

In a unanimous decision, the Supreme Court of the United States recently determined in Connelly v. U.S. that the value of a life insurance policy must be included in the fair market value of a closely held business for...more

Bond Schoeneck & King PLLC

Life Insurance and Tax Implications

Bond Schoeneck & King PLLC on

Amidst many recent sharply divided decisions, the United States Supreme Court (SCOTUS) on June 6, 2024 issued a rare unanimous ruling in Connelly v. United States, which addressed estate tax considerations relative to...more

Baker Donelson

Supreme Court Upholds Life Insurance Valuation in Estate Tax Calculation

Baker Donelson on

The United States Supreme Court (Supreme Court) released the Connelly v. United States opinion on June 6, 2024. The opinion affirmed the Eighth Circuit's holding in favor of the IRS that a company's contractual redemption...more

Rivkin Radler LLP

BEWARE: Redemption Agreement Funded with Corporate-Owned Life Insurance

Rivkin Radler LLP on

On June 6, 2024, in the case of Connelly v. United States, the United States Supreme Court determined that corporate-owned life insurance proceeds used to redeem a decedent’s shares in the corporation must be included when...more

Warner Norcross + Judd

Connelly v. United States Decision Affects Life Insurance for Closely Held Business Owners

Warner Norcross + Judd on

On June 6, 2024, the United States Supreme Court issued its opinion regarding Connelly, as Executor of the Estate of Connelly v. United States. This final decision will directly impact all closely held business owners that...more

Mayer Brown

Closely-Held Corporation Buy-Sell Arrangements Upended by Supreme Court in Estate of Connelly

Mayer Brown on

The Supreme Court has just weighed in on how gift and estate taxes apply with respect to non-cash gifts in Estate of Connelly v. United States. The Court’s opinion closely follows the economics of such arrangements, but...more

Perkins Coie

Supreme Court Clarifies Estate Tax Consequences for Closely Held Company

Perkins Coie on

The Supreme Court of the United States issued an important ruling on June 6, 2024, clarifying the federal tax consequences of certain succession plans for closely held businesses. The Court held in Connelly v. United States,...more

Burns & Levinson LLP

Client Advisory: Valuing Closely-Held Stock for Estate Tax Purposes | Connelly v. U.S.

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Connelly v. United States involved determining the fair market value of a closely-held corporation for purposes of estate taxation. A corporation, owned by two brothers, was obligated to buy back the shares of the first to...more

ArentFox Schiff

US Supreme Court Affirms the Eighth Circuit’s Decision in Favor of the Government Concerning the Estate Tax Treatment of Life...

ArentFox Schiff on

In Connelly v. US, 602 US ___ (6/6/2024), the US Supreme Court affirmed a decision of the US Court of Appeals for the Eighth Circuit in favor of the government concerning the estate tax treatment of life insurance proceeds...more

DarrowEverett LLP

Buy, Sell, Pay Taxes: SCOTUS Decision Places Its Own Premium on Buy-Sell Insurance

DarrowEverett LLP on

All U.S. closely held businesses just received a warning from the highest court in the land that they should review their succession plans (or else risk a higher tax bill for the estates of their owners). On June 6, 2024, the...more

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