News & Analysis as of

Estate Tax Internal Revenue Service

Estate taxes, also known as inheritance or death taxes, are taxes on an individual's right to transfer property at death.
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The proposed regulations update outdated references and information under the current regulations, including references to temporary regulations, IRS officials, offices and addresses.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

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

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

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

Farrell Fritz, P.C.

Beware of Company-Owned Life Insurance - Connelly v. United States

Farrell Fritz, P.C. on

On June 6, 2024, the Supreme Court unanimously decided the case of Connelly v. United States, which concerned the valuation of a business with company-owned life insurance. In this case, two brothers were the sole...more

BakerHostetler

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

BakerHostetler on

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

Allen Barron, Inc.

Connelly v Internal Revenue Service

Allen Barron, Inc. on

Connelly v. Internal Revenue Service is a landmark SCOTUS decision that will impact business owners, partners, shareholders, members, and professional practitioners from a business perspective, succession planning, as well as...more

Tucker Arensberg, P.C.

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

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

Warner Norcross + Judd

Current Tax Laws That Will Expire After 2025 if Congress Does Not Act

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The Tax Cuts and Jobs Act (TCJA), which became effective on January 1, 2018, made significant changes to tax legislation that impacted individuals, families, business owners and companies. Some changes were intended to be...more

Hinckley Allen

Supreme Court Decision Yields Significant Impacts for Closely Held Businesses

Hinckley Allen on

On June 6, 2024 the Supreme Court unanimously ruled that life insurance proceeds should be included in the fair market valuation of a corporation for federal estate tax purposes. In Connelly v. United States, the Supreme...more

Foster Swift Collins & Smith

Business Owners: How to Avoid Additional Estate Taxes after Connelly v. Commissioner

In early June, the Supreme Court issued an opinion that clarifies how company-owned life insurance impacts the value of the company for estate tax purposes. As a business owner, you may need to re-evaluate the use of those...more

Whiteford

Client Alert: Time to Revisit Buy-Sell Agreements in the Wake of the Connelly Decision

Whiteford on

In its recent decision in Connelly v. U.S., the U.S. Supreme Court held that life insurance proceeds received by a corporation to fund an obligation to purchase a deceased stockholder’s shares in the corporation must be...more

Miles & Stockbridge P.C.

Supreme Court Case Adversely Impacts Parties to Buy-Sell Arrangements

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

Rivkin Radler LLP

Funding the Buyout of a Deceased Shareholder With Corporate-Owned Life Insurance – Did the Court Decide Connelly Correctly?

Rivkin Radler LLP on

You may have heard or even read about the U.S. Supreme Court’s recent decision regarding the date of death value of a deceased shareholder’s shares in a closely held corporation that owned a life insurance policy on the...more

Bond Schoeneck & King PLLC

Life Insurance and Tax Implications

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

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