News & Analysis as of

Irrevocable Trusts Internal Revenue Code (IRC)

Kohrman Jackson & Krantz LLP

Act Now or Pay Later? Estate Planning Strategies Before the 2025 Tax Sunset

The current federal estate tax exemption levels, introduced by the Tax Cuts and Jobs Act (TCJA) in 2018, have provided historically high federal estate tax exemptions. But this period of increased exemption is expected to...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

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

Blank Rome LLP

IRS Disallows Step-Up in Tax Cost Basis for Assets Held by an Irrevocable Grantor Trust

Blank Rome LLP on

Under current law, assets acquired from a decedent receive an adjustment in cost basis to fair market value, thereby potentially eliminating significant unrealized gain. Although Congress has and likely will use this tax...more

Gray Reed

IRS Takes Warning Shot at Section 643(b) Trust Arrangements

Gray Reed on

For some time, promoters have shopped around an arrangement known as a “section 643(b) trust,” known alternatively as a “non-grantor, irrevocable, complex, discretionary, spendthrift trust.”  On August 9, 2023, IRS Chief...more

Proskauer Rose LLP

Wealth Management Update - April 2023

Proskauer Rose LLP on

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

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

Genova Burns LLC

IRS Rules Gift Splitting Differs for Gift and GST Tax Purposes

Genova Burns LLC on

In PLR 201811002 the IRS has ruled that gift splitting works differently when applied to Gift taxes and Generation Skipping Transfer (GST) taxes. Gift splitting is authorized by IRC Section 2513(a)(1) and states, generally,...more

Katten Muchin Rosenman LLP

2016 Year-End Estate Planning Advisory

In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more

Foley & Lardner LLP

Exclusion for Qualified Small Business Stock

Foley & Lardner LLP on

The Protecting Americans from Tax Hikes Act, passed in December 2015, extended an often overlooked provision of the tax code with the potential to provide significant savings to small business owners and non-corporate...more

Proskauer Rose LLP

Wealth Management Update - October 2015

Proskauer Rose LLP on

October Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The October § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more

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