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
Taking the Sting Out of Death Taxes with Dylan Metzner, Jones & Keller
Gift Tax Basics
NGE On Demand: GRAT Trusts with Eric Mann
To Give or Not to Give: Considerations for Year-End Gifting
ATTENTION ALL CADETS!
In the world of farming and ranching, ensuring your land's future is vital. That's where agricultural estate planning comes in. It's all about smoothly transitioning your farm or ranch to the next generation, maintaining its...more
Earlier this week the White House released its Fiscal Year 2025 Budget. Of course, the federal government has not yet adopted a budget for the Fiscal Year 2024 even as we approach that year’s halfway mark. But I digress. The...more
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
Same old in D.C.- On Monday, November 15, the President will sign into law the approximately $1 trillion Infrastructure Investment and Jobs Act that was finally passed by Congress when the House approved the Senate’s...more
It was quite a week, wasn’t it?- Manchin- Senator Manchin continued to attract a lot of attention. To the dismay of his fellow Democrats, the West Virginian – who also chairs the Senate Energy and Natural Resources...more
What You Should Know •The House Ways and Means Committee has approved the tax provisions of President Biden’s Build Back Better Act, a significant first step towards passage. •If passed as drafted, the proposed...more
On September 13, the House Ways and Means Committee released a proposed plan to pay for the $3.5 trillion Build Back Better Act (the “Act”). The proposed legislation contains a variety of changes across the tax code, but the...more
As we enter the final quarter of 2021, there are many things still to do and plan for before the end of the year. There are also some timing considerations given proposed legislative changes and the lead time needed to...more
It is said that two things are certain in life: death and taxes. True, but incomplete. What is missing from this short list is a third inevitable occurrence – tax law changes. We now have a new and pressing series of proposed...more
First Step- Last Wednesday, the House Ways and Means Committee approved that portion of the 2022 budget legislation with which it was tasked by the Congressional Budget resolution of August 24. The text of the bill...more
Recap- Last week, we considered several of the revenue proposals included in the Biden Administration’s 2022 Budget that are probably of interest – or should we say, “of concern”? – to the owners of closely held...more
Here are five things to remember when performing the valuation of shares of a closely held entity for gift and estate tax reporting...more
The stock market has had record declines and many businesses are shuttered, at least temporarily. Long-term prospects may still be positive but in the near-term the value of many entities has reduced. Are there transactions...more
May Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The May § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs...more
IRS issues new proposed rules aimed at eliminating valuation discounts for transfers of interests in family-controlled entities. Clients considering making transfers of interests in such entities should act soon....more
Transfers of Family-Controlled Business Entities to Family Members Could Get More Expensive - The Internal Revenue Service (IRS) recently released proposed regulations that will dramatically change the valuation of...more
Chapter 14 of the Internal Revenue Code consists of four Code Sections (Sections 2701 – 2704) designed to close valuation loopholes. Prior to Congress’s enactment of Chapter 14 in 1990, estate planners had a host of tools...more
The IRS has expanded the scope of IRC Section 2704 by issuing proposed regulations that seek to limit the availability of valuation discounts for transfers of interests in family-controlled entities. In general, the purpose...more
Earlier this month, the IRS issued long-awaited proposed regulations under Section 2704 of the Internal Revenue Code that, if adopted, will have a substantial impact on traditional estate planning techniques commonly utilized...more
On August 2, 2016, the Internal Revenue Service (IRS) released proposed regulations that, when finalized, will affect clients holding and transferring interests in family-controlled entities. Family limited partnerships...more
Recently proposed Treasury Regulations (“Proposed Regulations”), if enacted as proposed, would curtail valuation discounts that currently reduce the value of certain business interests transferred during life or at death for...more
The IRS has at last issued long-anticipated proposed regulations under Code §2704. We perceive the proposed regulations as an attempt by the IRS to curtail the use of discounts – such as minority interest and lack of...more
Action Item: Owners of family businesses and investment entities (such as family limited partnerships, limited liability companies (“LLCs”), and corporations) are urged to consider making transfers of interests in those...more
High net worth families often utilize family entity structures, such as limited partnerships or limited liability companies, in order to provide for the coordinated management of family assets and move wealth to younger...more
Gifts and bequests of interests in family-owned companies have traditionally been valued at their fair market values for purposes of calculating the gift or estate tax on the transfer. In valuing these transfers, there is...more