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Gift Tax Tax Liability

Lewis Roca

Supreme Court Decision in Connelly v. United States

Lewis Roca on

On June 6, 2024, the United States Supreme Court issued its decision in in Connelly, As Executor of the Estate of Connelly v. United States, (602 US ________). The decision involves the application of the federal estate tax...more

Strafford

[Webinar] New IRS Guidance on Basis Adjustments for Irrevocable Grantor Trusts: Key Issues for U.S. and Non-U.S. Persons - June...

Strafford on

This CLE/CPE webinar will provide estate planners insight on recently issued IRS guidance regarding basis adjustments for irrevocable grantor trusts. The panelist will discuss key items and challenges stemming from Revenue...more

Adler Pollock & Sheehan P.C.

It’s Time to Take Another Look at the Stepped-Up Basis Rules

Thanks to a generous federal gift and estate tax exemption amount ($13.61 million for 2024), only the wealthiest of families are exposed to estate tax liability. For many, this means that estate planning now has a stronger...more

Gray Reed

IRS Concedes Yet Another Form 3520 Related Penalty Case

Gray Reed on

United States citizens and residents are often not aware of the myriad of foreign information return filing obligations that exist under federal tax laws.  For example, buried within the Code are reporting obligations...more

Bilzin Sumberg

Inflation Adjustments for 2024: Key Information for International Private Client Practitioners

Bilzin Sumberg on

The IRS recently released its inflation adjustments for 2024. International private client practitioners should note the following: US Estate and Gift Tax Exclusion Amount: $13,610,000 (up from $12,920,000)...more

Rivkin Radler LLP

Disclaiming to Save Taxes

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It’s not enough for the founder of a closely held business to have successfully established the business. The business has to grow, not only to increase profits, but also to make it more competitive and to diversify its...more

Rivkin Radler LLP

Corporate-Owned Life Insurance, a Redemption, and The Value of a Decedent’s Stock

Rivkin Radler LLP on

Estate Tax – It’s a Killer- One of the reasons often given for eliminating the estate tax is the substantial economic burden it places upon the estate of a deceased business owner and upon the business itself. Specifically,...more

Freeman Law

Tax Court in Brief | Estate of Spizzirri v. Commissioner | Gifts, Bequests, Deductible Expenses, and Estate Tax

Freeman Law on

Short Summary. Decedent was a wealthy lawyer and investor. During the last few years of his life, decedent paid significant sums to one of his daughters, one of his stepdaughters, and multiple women with whom he was either...more

Freeman Law

Why You Should Hire a Tax Professional to Review Your Trust

Freeman Law on

Trusts come in many variations, rendering them often difficult for non-attorneys to follow and comprehend.  Indeed, this variation can often be seen in the nomenclature used for trust arrangements, which includes terms such...more

Adler Pollock & Sheehan P.C.

Estate Planning Pitfall: You Sell Real Estate for $1

Someone may have told you a story along these lines: Years ago, my grandfather bought land along the shore in (fill in a desirable resort area) for $1,000. He built a vacation home on the property for $50,000 and his family...more

Foster Garvey PC

Disregarded Entities Under the Check-the-Box Regulations Are Not Disregarded for All Tax Purposes

Foster Garvey PC on

More than 25 years ago, effective January 1, 1997, Treasury issued what have been called the “Check-the-Box” regulations (the “Regulations”). The Regulations ended decades of battles between taxpayers and the IRS over entity...more

Freeman Law

Foreign Gifts | When Do You Have To Report Them?

Freeman Law on

Foreign Gifts and IRS Reporting - U.S. persons who receive gifts or bequests from foreign persons beware—these gifts or bequests may need to be reported to the Internal Revenue Service (“IRS”). The consequences for failing...more

Rivkin Radler LLP

Wendy And Jen Wreck the Movies – Citizen Kane (1941) Or Deposit Money, Not Children, in the Bank

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“Legendary was the Xanadu where Kubla Kahn decreed his stately pleasure dome.” Legendary too were the colossal errors made by Mary Kane in this celebrated classic movie which follows a journalist as he tries to uncover the...more

Rivkin Radler LLP

One Step Closer to “Building Back” – Where Do Federal Transfer Taxes Stand?

Rivkin Radler LLP on

Tax the Rich? The President’s plan for a tax regime that would ensure the rich pay their “fair share” of the cost of implementing his programs has come one step closer to being realized . . . maybe . . . well, sort of ....more

Bowditch & Dewey

Tax Tips for GoFundMe Donors and Organizers

Bowditch & Dewey on

Since January of 2020, over 175,000 COVID-19 related GoFundMe campaigns were created, raising more than $416 million. While donors may be feeling charitable, they should know that their contributions are likely not...more

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

Foster Garvey PC on

...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposals for Trusts, Estates, and Retirement Accounts

Bowditch & Dewey on

In this second blog post on the House Ways and Means Tax proposals, we address the proposed changes that will affect the taxation of trusts, estates, and retirement plans. As we discussed, on September 13, 2021, the...more

Adler Pollock & Sheehan P.C.

Estate Planning Pitfall: You Don’t Meet the Tax Requirements For Splitting Gifts

The annual gift tax exclusion is a powerful tool in the estate planning toolbox. When using your annual exclusion, you don’t owe any gift tax on amounts transferred to another person up to a specified limit. The limit is...more

Bilzin Sumberg

How Do I Become a U.S. Taxpayer? Let Me Count the Days

Bilzin Sumberg on

What does it mean to be a U.S. income taxpayer? Very simply, it means that you are taxable on your worldwide income and gains, even if you don't live full-time in the U.S. Any U.S. citizen is likely already familiar with this...more

Rivkin Radler LLP

The President’s Recent Tax Proposals: What Do They Mean For Business Owners?

Rivkin Radler LLP on

A Night to Remember? Did you listen to the President’s speech last Wednesday? He addressed a joint session of Congress to pitch the Administration’s $1.8 trillion American Families Plan. Due to COVID-related...more

Holland & Knight LLP

Tax Liability Issues to Consider for High-Net-Worth Couples in Divorce

Holland & Knight LLP on

Divorce is not a topic most clients or tax advisors enjoy discussing. Nevertheless, it is important in today's day and age to advise clients, especially high-net-worth individuals with substantial assets located in the U.S....more

Foster Garvey PC

Tax Planning Out of Fear Usually Doesn’t End Well

Foster Garvey PC on

It is not unreasonable to anticipate that there will be a federal tax policy transformation following a change in the political control of the White House, the U.S. Senate and the U.S. House of Representatives. What may be...more

Adler Pollock & Sheehan P.C.

Consider All the Angles of Joint Ownership

Estate planners generally tout the virtues of owning property jointly — and with good reason. Joint ownership offers several advantages for surviving family members. But this shouldn’t be viewed as a panacea for every estate...more

Bilzin Sumberg

Foreign Clients: Take Care When Making Gifts This Holiday Season

Bilzin Sumberg on

With the holiday season upon us, we thought it would be a good idea to review some of the gift tax rules uniquely applicable to foreign clients. This post examines the rules surrounding one type of gift in particular – the...more

Rivkin Radler LLP

The Time to Plan for Tax Code Changes Is Now

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The election is only weeks away, and with it is likely to come significant changes to the tax code. Many economists anticipate that, regardless of the outcome, there will likely be tax increases to reduce the federal deficit,...more

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