News & Analysis as of

Internal Revenue Code (IRC) Trusts Internal Revenue Service

McDermott Will & Emery

IRS Roundup March 15 – March 28, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 15, 2025 – March 28, 2025. IRS GUIDANCE - March 17, 2025: The IRS issued Revenue Ruling 2025-8, providing...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

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

ArentFox Schiff

The Big Six Items That Family Offices Need to Consider in 2025

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Across all industries, family offices and their owners and management teams face rapidly evolving challenges, opportunities, and risks in the dynamic environment that is 2025. Here are six issues that family offices should...more

Proskauer Rose LLP

Wealth Management Update - March 2025

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March 2025 AFRs and 7520 Rate - The March 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.40%, which was the same as the February 2025 rate...more

Gray Reed

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

Gray Reed on

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

Davis Wright Tremaine LLP

Watch the Sunset: Federal Estate Exclusion Set To Shrink in 2026; New Changes on the Horizon

The 2017 Tax Cuts and Jobs Act (TCJA) is set to end at the close of this year, resulting in a federal estate exclusion that is less than half of the current $13.99 million exclusion. Other changes to the tax structure are...more

Proskauer Rose LLP

Wealth Management Update - February 2025

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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

Offit Kurman

The Estate Planning Benefits of Marriage: What Unmarried Couples Need to Know

Offit Kurman on

It is becoming increasingly commonplace for people to enter long-term romantic relationships without legally marrying. While there are no exact statistics on how many Americans fall into this growing category, a 2019 Pew...more

Holland & Knight LLP

Trident Trust Investigation: Implications for Clients and Advisors

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The U.S. Department of Justice (DOJ) and the IRS have issued a John Doe summons targeting Trident Trust and related companies in three federal court cases. This development has significant implications for clients of Trident...more

Cohen Seglias Pallas Greenhall & Furman PC

Breaking Down the IRS's 2025 Inflation Adjustments for Estate and Gift Planning

The IRS has released new inflation-adjusted figures that can impact your estate and gift planning. These numbers seem like a lot to sift through, but understanding them could make a big difference in your financial future....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

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

Vorys, Sater, Seymour and Pease LLP

The Importance of Actively Monitoring S Corporation Compliance

Many banks have elected to be “S Corporations” for tax purposes. This status can provide significant tax benefits to the bank’s shareholders, but it also comes with several ongoing technical requirements. Failure to satisfy...more

Proskauer Rose LLP

Wealth Management Update - January 2025

Proskauer Rose LLP on

The January 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.2%, an increase from the December 2024 rate of 5.0%. The January applicable federal rate (“AFR”) for use with...more

ArentFox Schiff

A Tale of Two Recent QTIP Trust Termination Cases — Anenberg and McDougall

ArentFox Schiff on

Through the years, the US Tax Court has provided significant clarification on the gift tax consequences of terminating qualified terminable interest property (QTIP) trusts. Two new cases in 2024, Estate of Sally J. Anenberg...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

ArentFox Schiff

The Sunset of the Doubled Estate, Gift, and GST Tax Exclusion Amounts After December 31, 2025

ArentFox Schiff on

The TCJA doubled the lifetime exclusion and GST tax exemption. This exclusion amount, adjusted for inflation, is now $13.61 million and is expected to be approximately $13.99 million in 2025. However, in 2026, the amount will...more

Husch Blackwell LLP

Understanding the 2026 Changes to the Estate, Gift, and Generation-Skipping Tax Exemptions

Husch Blackwell LLP on

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

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

DarrowEverett LLP

Maximizing QSBS Benefits with Estate Planning: The Art of Stacking

DarrowEverett LLP on

The number of taxpayers seeking the benefits of Qualified Small Business Stock (“QSBS”) has picked up steam in recent years, particularly since the Tax Cuts and Jobs Act (“TCJA”) lowered the federal corporate tax rates to...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part III – Code...

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This third installment of my multi-part series on Subchapter S is focused on a single Code Section, namely IRC Section 1361(b)(1)(C) and the ineligibility of nonresident aliens as shareholders of Subchapter S corporations....more

McDermott Will & Emery

West Coast Forum 2023 | Key Takeaways

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McDermott’s Private Client Practice led interactive discussions on a broad range of topics pertinent to ultra-high-net-worth families, their family office representatives and other advisors at our Private Client West Coast...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

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