News & Analysis as of

Internal Revenue Code (IRC) Tax Liability Estate Tax

A&O Shearman

Summary of key provisions in House reconciliation bill

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On May 22, 2025, the U.S. House of Representatives narrowly passed the House budget reconciliation bill (H.R. 1) (the “House Bill”) by a party-line vote of 215 – 214. The House Bill, which includes significant tax law...more

Rivkin Radler LLP

Terminating a Trust? Don’t Forget to Consider This Tax Issue

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Every conveyance of property or of an interest in property from one person to another is prompted, or at least influenced, by economic considerations. The parties to the transaction may swap properties, or one party may...more

Freeman Law

Residency for Federal Taxation

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Residence may seem to be a relatively simple thing to determine. It’s where you live, right? Well, leave it to the Internal Revenue Code to complicate this question. There are different tests for residency when it comes to...more

Rivkin Radler LLP

“Hey Mom, Can I Have A Few Bucks?” Is It A Loan? A Gift? A Little of Each?

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A parent will sometimes transfer money to a child to enable the child to make an investment that the child could not otherwise make on their own. For example, the child may have identified an attractive business opportunity...more

Lippes Mathias LLP

Countdown to Tax Changes: Navigating Budget Reconciliation 2025

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As the clock ticks down to the end of 2025, the impending sunset of key provisions of the Tax Cuts and Jobs Act (“TCJA”) looms large, threatening tax hikes for millions of Americans. With Congress at a crossroads, the...more

Gray Reed

Understanding IRS Private Letter Ruling 202504006: Crucial Takeaways for Tax Planning

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The Internal Revenue Service (IRS) recently issued Private Letter Ruling (PLR) 202504006, addressing several important estate and gift tax questions related to the division of a marital trust and the subsequent disclaimer of...more

Kohrman Jackson & Krantz LLP

Act Now or Pay Later? Will Congress Extend the Higher Estate Tax Exemption Before 2026?

As we approach the end of the first quarter of 2025, estate planners and their clients are closely monitoring developments in Washington, D.C. The scheduled sunset of the increased estate and gift tax exemption is now less...more

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

Still the One! – The Use of Private Placement Life Insurance in Tax Planning for Trial Attorneys with Contingency Fee Income

In the Soundtrack of Our Lives, one of the songs that I still get to hear from time to time on Sirius XM, is “Still the One” which was recorded and released by the band Orleans in 1976. I was in the tenth grade just to be...more

Cadwalader, Wickersham & Taft LLP

Leaked Memorandum Details Possible House Tax Proposals

On February 12, 2025, the House proposed a budget resolution that earmarked up to $4.5 trillion for tax cuts over the next ten years.  While the House has yet to elaborate on specific tax cuts or legislation, a widely...more

Proskauer - Tax Talks

Tax Proposals Potentially Being Considered by the U.S. House Budget Committee in Reconciliation

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On January 17, 2025, multiple news outlets and other sources reported the existence of a memorandum circulated by the U.S. House of Representatives Budget Committee to the House Republican Caucus (the “Memorandum”) containing...more

Rivkin Radler LLP

Will the Federal Estate and Gift Tax Exemption Be Reduced in 2026?

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The federal estate and gift tax exemption changes from year to year. The current combined federal estate and gift tax exemption amount of $13.99 million per person ($27.98 million per married couple) is scheduled to “sunset”...more

Rivkin Radler LLP

Expiring Federal Transfer Tax Benefits – Nothing is Certain or Lasts Forever

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Just a few weeks ago, many individual taxpayers, driven by what they viewed as the relatively imminent expiration of the enhanced federal transfer tax exemptions, sought advice on how to leverage their remaining exemption and...more

Jaburg Wilk

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

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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

Gray Reed

The Fine Print: IRS Examination of Artwork

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Many taxpayers have art collections. However, the art collections of some high-net-worth individuals, family offices, and business taxpayers may draw the unwanted eye of the IRS. With the increased focus on auditing...more

Bilzin Sumberg

Inflation Adjustments for 2024: Key Information for International Private Client Practitioners

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The IRS recently released its inflation adjustments for 2024. International private client practitioners should note the following: US Estate and Gift Tax Exclusion Amount: $13,610,000 (up from $12,920,000)...more

Lerch, Early & Brewer

IRS Levy Allowed on Classic Italian Cello to Satisfy Outstanding Estate Tax Liabilities

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United States v. Firestone - In United States v. Firestone, the United States (Government or U.S.) sought to enforce a judgment against Defendant Omar Firestone (Omar) for outstanding tax liabilities related to the Estate of...more

Rivkin Radler LLP

Transferee Liability for Estate Tax: The Downside of Being a Beneficiary

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Death of a Parent- In the context of a family-owned business, it is often the case that the matriarch or patriarch of the family is also the chief executive of the business. They may have founded the business, or they may...more

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

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...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more

Coblentz Patch Duffy & Bass

2020 Tax Planning: Benefits of GRATs

Now may be an opportune time to gift assets out of your estate, particularly through an estate planning technique known as the Grantor Retained Annuity Trust (“GRAT“)—a small silver lining of the alarming pandemic and down...more

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