Once Removed Episode 18: The Reciprocal Trust Doctrine
The May 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.00%, which is the same as the April 2025 Section 7520 rate...more
The April 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.00%, which is 0.40% less than the March 2025 rate. The April applicable federal rate (“AFR”) for use with a...more
February 2025 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The February applicable federal rate (“AFR”) for use with a sale to a defective grantor...more
The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...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
A trust structure, commonly used for estate planning, can be problematic in certain civil law jurisdictions, such as those in many European countries. Recent acts enacted in Wyoming and New Hampshire allow for the...more
Some folks eagerly await the release of a new album. Others camp outside of big box retailers to get the jump on holiday gifts. There are those who line up at box offices to purchase tickets for a concert that is months away....more
Most of you know by now that I grew up in the Panama Canal Zone which no longer exists as of 1999. In that respect, the transition left me as a man without a country. My father (of blessed memory) when referring to kids...more
Everyone knows about the income and estate tax changes included as part of the Tax Cuts and Jobs Act of 2017 (the “Act”), but there are several overlooked provisions that may significantly affect taxation in a divorce. Some...more
On Friday, July 13, 2018, the U.S. Department of the Treasury (the “Treasury”) and the IRS published Notice 2018-61 (the “Notice”), stating that they plan to issue regulations providing clarification of the effect of § 67(g)...more