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Internal Revenue Code (IRC) Beneficiaries

Proskauer Rose LLP

Wealth Management Update - April 2025

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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

Allen Barron, Inc.

Create a New Trust or Update an Existing Estate Plan

Allen Barron, Inc. on

If you wish to create a new trust or update an existing estate plan, you will need skill and expertise across many disciplines: tax, estate planning, and legal services. Look for a service provider who can seamlessly...more

Foley & Lardner LLP

Benefits Basics - When an Employee Dies: A Resource Guide for HR & Benefits Professionals

Foley & Lardner LLP on

As a member of your company’s human resources or employee benefits department, one of the most difficult calls you may receive is from a colleague or an employee’s family member notifying you of the death of an employee. This...more

Adler Pollock & Sheehan P.C.

How an HSA Can Benefit Your Estate Plan

A Health Savings Account (HSA) can positively affect your estate plan. How? In addition to serving as a viable option to reduce health care costs, an HSA’s funds grow on a tax-deferred basis. In fact, an HSA is similar to a...more

Offit Kurman

Equal Shares, Unequal Outcomes: Estate Planning Strategies for Parents and their Qualified Retirement Accounts

Offit Kurman on

Typically, a parent wishes to treat their children equally in their estate plan and presumes they will achieve this goal by dividing all their assets into equal shares upon their death. Accordingly, they will designate their...more

Allen Barron, Inc.

A Foreign Trust Creates Complex IRS Reporting Requirements

Allen Barron, Inc. on

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

Jaburg Wilk

Exclusions, Exemptions, Estate Tax – What to Know in 2025

Jaburg Wilk on

As we enter 2025, it’s important to stay informed about the current federal estate and gift tax laws, including annual exclusion limits and significant changes anticipated by the end of this year. Annual Exclusion Amount- ...more

Cole Schotz

Death, Taxes and Shareholder Agreements: Lessons from the Connelly Case

Cole Schotz on

Recently, the U.S. Supreme Court ruled unanimously in Connelly v. United States, that the valuation of a decedent’s shares in a closely held corporation for federal estate tax purposes must include insurance proceeds received...more

Proskauer Rose LLP

Wealth Management Update - December 2024

Proskauer Rose LLP on

December 2024 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split-Interest Charitable Trusts - The December Section 7520 rate for use in estate planning techniques such as CRTs, CLTs,...more

Proskauer - Employee Benefits & Executive...

Benefit Plan Deadlines Extended for Individuals Affected by Recent Natural Disasters

Last week, the U.S. Departments of Labor and Treasury issued a Joint Notice requiring the extension of certain benefit plan deadlines for individuals affected by Hurricanes Helene and Milton and Tropical Storm Helene.[1] The...more

DarrowEverett LLP

How Will New Congress Impact Tax and Estate Planning Strategies?

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With the looming elections, tax planners have taken time to consider what the future of Estate and Gift Tax planning might be under the new Congress. Every new Congress considers changes to the Internal Revenue Code of 1986,...more

Bricker Graydon LLP

Final Warning: Distributions to Beneficiaries Must Begin in 2025

Bricker Graydon LLP on

The retirement plan industry has been wrestling with the changes to required minimum distribution (RMD) provisions made by the SECURE Act and SECURE 2.0. One issue in particular has caused considerable confusion....more

Husch Blackwell LLP

Unanimous Supreme Court Determines Company-Owned Life Insurance Increases Fair Market Value

Husch Blackwell LLP on

On June 6, 2024, the Supreme Court held 9-to-0 in Connelly v. United States that company-owned life insurance increases the company’s fair market value for estate tax purposes, and the company’s obligation to redeem a...more

Pillsbury - Propel

Estate Planning for Founders - Part II: Planning with Qualified Small Business Stock

Pillsbury - Propel on

This is the second of a four-part series focusing on estate planning fundamentals for founders. This article will address an important topic for owners of Qualified Small Business Stock (QSBS) as defined in Section 1202 of...more

Kohrman Jackson & Krantz LLP

Navigating Section 1014 and the TCJA: A Deep Dive into the IRS Ruling on Basis Adjustments

Understanding the nuances of the Internal Revenue Code (I.R.C.) is crucial for effective estate planning and tax strategy. For example, estate planners must be familiar with the tax basis adjustment provisions in 26 U.S.C. §...more

Rivkin Radler LLP

Trust Beneficiary Engages In Like Kind Exchange Using Trust Property

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It is a basic principle of the income tax that the gain or loss realized by a taxpayer from the conversion of property into cash, or from the exchange of property for other property that differs materially in kind from the...more

Pillsbury Winthrop Shaw Pittman LLP

U.S.-Based Statutory Foundations: the Best of a Trust and a Non-Trust?

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

Cozen O'Connor

Pennsylvania Amends Tax Treatment of Grantor Trusts As of January 1, 2025

Cozen O'Connor on

Starting January 1, 2025, the individual who is the grantor of a trust that qualifies as a grantor trust under Sections 671 through 679 of the Internal Revenue Code will himself or herself be subject to Pennsylvania Personal...more

Dechert LLP

Individuals and Trusts Beware: The Corporate Transparency Act Applies to You

Dechert LLP on

The Corporate Transparency Act (the "Act") is a significant piece of legislation enacted as part of the National Defense Authorization Act for Fiscal Year 2021. The Act was designed to prevent the misuse of corporations and...more

Seward & Kissel LLP

DOL Proposes to Expand the Definition of an ERISA Fiduciary

Seward & Kissel LLP on

On November 3, 2023, the U.S. Department of Labor (DOL) proposed a collection of regulatory changes in its ongoing quest to update the definition of a “fiduciary” under ERISA and Section 4975 of the Internal Revenue Code (the...more

Keating Muething & Klekamp PLL

Estate Planning Update: Recent IRS Ruling Offers a Stark Reminder of the Benefits of Proper Estate Planning for Retirement...

Despite ultimately finding in favor of a taxpayer surviving spouse, IRS Private Letter Ruling 2023-22-014 (the “PLR”) is chock-full of reasons to ensure proper planning is in place when it comes to IRAs....more

Mitchell, Williams, Selig, Gates & Woodyard,...

Think Twice Before You End A Trust – Income Tax Consequences of Trust Commutations and "Early Terminations"

Despite the Rule Against Perpetuities (which basically says a trust can’t go on forever) being repealed in many states, most trusts, as a practical matter, don’t go on forever. In an ideal scenario, the terms of the trust...more

Freeman Law

Section 643(b) and Trusts

Freeman Law on

Recently, there seems to be some confusion regarding section 643(b) of the Internal Revenue Code of 1986, as amended (the “Code”), and its application to trusts. Indeed, that provision—particularly to those not well-versed in...more

Harris Beach Murtha PLLC

Retirement Accounts: Much Needed Clarity Regarding the 10-Year Rule

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Americans hold a considerable percentage of their wealth in retirement accounts. Recent changes to the Internal Revenue Code (the “Code”), as well as proposed regulations, have introduced new rules altering the required...more

Gerald Nowotny - Law Office of Gerald R....

Family Affair – Introducing Family Office Life Annuity™ (aka FOLA™)

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

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