Once Removed Episode 19: The Step-Transaction Doctrine and the Case of Smaldino
Once Removed Episode 18: The Reciprocal Trust Doctrine
Once Removed Episode 16: Gift and Estate Tax, Inflation Adjustments for 2024
Once Removed Episode 17: Annual Gifting to Individuals: Options, Opportunities and Pitfalls
To Give or Not to Give: Considerations for Year-End Gifting
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
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
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
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 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
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
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
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
One of the key changes of the 2010 Tax Relief Act is the addition of “portability” of the first deceased spouse’s unused basic exclusion amount, commonly referred to as the deceased spousal unused exclusion amount. Under...more
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
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
As we have discussed in previous newsletters, the concept of “portability” introduced in 2012 allows a surviving spouse to use the unused federal estate tax exemption of the first spouse to die, but only if a federal estate...more
Maryland’s estate tax is changing. On May 15, 2014, Governor O’Malley signed into law H.B. 739. The current Maryland estate tax exemption is $1 million per individual. ...more
As discussed in a prior post, one of the helpful provisions recently added to federal estate tax law allows a surviving spouse to use any “leftover” or “unused” federal estate tax exclusion amount of a deceased spouse. The...more