Once Removed Episode 18: The Reciprocal Trust Doctrine
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
April Interest Rates for GRATS, Sales to Defective Grantor Trusts, Intra-Family Loans and Split-Interest Charitable Trusts - The April Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and...more
The April Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.0%. The April applicable federal rate (“AFR”) for use with a sale to a defective grantor trust or intra-family loan...more
Many estate planning strategies involve leveraging low interest rates in order to transfer the appreciation of an asset to beneficiaries free from transfer taxes. Generally, these techniques enable senior family members to...more
“Déjà vu All Over Again”- The White House last week released the President’s Budget for the Fiscal Year 2023. The Budget is ambitious, but its “investments,” we are told, “are more than paid for with tax reforms focused on...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
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
You have probably heard that the House Ways and Means Committee released proposals for increasing gift and estate taxes in order support legislation being advanced by the Democratic majority in Congress. ...more
Key points •On Wednesday, September 15, The House Ways and Means Committee advanced a proposal for a $2.1 trillion tax increase. •The proposal could drastically change the gift and estate tax treatment of new...more
- Annual inflation-indexing continues to increase the historically high lifetime exemption amount for gift, estate, and generation-skipping transfer taxes. Those of considerable wealth who have not yet made gifts, such as...more
Astrid Owen leads this interactive webinar to discuss the US taxation of US beneficiaries and US settlors of non-US trusts. The benefit of using non-US grantor trusts established by a non-US person for US beneficiaries...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
I. INTRODUCTION - This outline is a selective and evolving review of the history of the modern federal estate tax. It originated during the attempts to repeal the estate tax in President Clinton’s second term and...more
The Department of the Treasury has released the Treasury Green Book for Fiscal Year 2017, which provides explanations of the President’s budget proposals. One such proposal (remember…these are just proposals, not actual...more
December Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The December Section 7520 rate for use with estate planning techniques such as CRTs, CLTs,...more