Once Removed Episode 18: The Reciprocal Trust Doctrine
On this episode of “Splitting Heirs,” Warren K. Racusin welcomes back Sharon L. Klein, President of Family Wealth for the Eastern US Region of Wilmington Trust Company and member of the Estate Planning Hall of Fame, to...more
Financial markets, political moods, and the world-at-large can take us on a roller coaster ride of ups and downs. But savvy investors (and their estate planning counsel) know that – in the end – neither the bears nor bulls...more
The Tax Cuts and Jobs Act of 2017 provided major changes to the Internal Revenue Code, specifically doubling the federal estate, gift, and generation-skipping transfer (GST) tax exemption (collectively, the exemption) from...more
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
This podcast often discusses the elements of a trust, and how to grant access, control and flexibility to beneficiaries and trustees. But for tax and other purposes, the donor typically cannot retain those kinds of powers. ...more
A Beneficiary Intentionally Defective Irrevocable Trust (BIDIT) provides a unique planning opportunity because it allows a beneficiary to continue to benefit from his or her own assets while maintaining some level of control...more
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
Until recently, there was a fair amount of comfort amongst practitioners that, when structured correctly, utilizing a tax reimbursement clause for a grantor trust did not produce any negative U.S. gift or estate tax results....more
Although the IRS is now on high alert for wealthy individuals, new and existing planning opportunities are available, such as tax-free gifts and other advantageous planning. Wealthy individuals and families should take...more
May 2023 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split-Interest Charitable Trusts - The May Section 7520 rate for use in estate planning techniques such as CRTs, CLTs, QPRTs and...more
A family vacation home offers an escape from the stresses of everyday life, and an opportunity for bonding. Parents return to their vacation homes year after year, creating memories with their children and grandchildren. If...more
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
Leveraging QPRTs in a High Interest Rate Environment - A Qualified Personal Residence Trust, or “QPRT” is a planning strategy specifically authorized in the Internal Revenue Code that allows an individual to remove a...more
The June Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 3.6%, an increase from the May rate of 3.0%. The June applicable federal rate (“AFR”) for use with a sale to a...more
Under the Internal Revenue Code’s “grantor trust” rules, the grantor of a trust may be treated as the “owner” of all or part of the trust. As such, the grantor is taxed on the trust’s income and reports its deductions...more
You likely are aware, from the news and our prior communications, that Congress currently is considering proposals that may have a significant impact on many estate plans. Although we still cannot be certain which, if any, of...more
In the recent case of Heiting v. United States, the Seventh Circuit Court of Appeals denied the taxpayer’s claim-of-right deduction pursuant to Internal Revenue Code section 1341. The case stemmed from the taxpayer’s attempt...more
Counting the Days?- We are 302 days away from the national mid-term elections, to be held November 8, 2022, yet the first full week of the new year has already highlighted some of the economic issues with which the...more
Certain revenue-raising proposals that would have affected the transfer tax regime and estate planning of high-net-worth individuals and trusts, which were included in the prior proposed bill in the House of Representatives,...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
The U.S. House of Representatives bill released last month proposes several changes to the current rules governing trusts where the grantor pays the income tax, but the value of which is not included in the grantor’s estate...more
Last month, the House Ways & Means Committee (the "Committee") approved draft legislation (the “Legislation”) as part of Congress' ongoing $3.5 trillion budget reconciliation process. The Legislation includes significant tax...more
Act Now Before the Window of Opportunity Closes - By now you have probably heard that the House Ways and Means Committee introduced legislation a few weeks ago (see Let the Estate Tax Planning Games Begin - But Where Will...more
On September 10, 2021, the U.S. House Committee on Ways and Means released a draft of proposed legislation that, if enacted into law, would reduce the estate tax exemption and significantly limit the effectiveness of certain...more
The U.S. House Committee on Ways and Means’ tax proposals would significantly impact estate planning for high net worth individuals if enacted. Gift, estate and GST exemption amounts would be decreased; grantor trusts would...more