Strategy Considerations for Global Litigation
As we’ve previously discussed, portability is an important feature of an estate plan. Portability allows the surviving spouse to die to “save” any of their predeceased spouse’s unused federal estate and gift exemption amount....more
As we start the new year, this Federal Tax Update highlights estate planning-related federal tax information that may be helpful as you consider planning options for 2024. ...more
In the technology world, portability has become increasingly important as people become more mobile and reliant on a variety of devices to access and use information. Portability allows individuals to work remotely or while...more
The IRS has announced the official estate and gift exclusion amounts for 2023. For an estate of any decedent dying during calendar year 2023, the applicable exclusion is increased from $12.06 million to $12.92...more
On July 8, 2022, the IRS issued Rev. Proc. 2022-32 that simplified the method for obtaining late relief for failure to timely make an estate tax portability election and extending the time for filing portability returns from...more
Effective July 8, 2022, the IRS issued Revenue Procedure 2022-32 to supersede Revenue Procedure 2017-34 and now allow for a late estate tax exemption portability election to be made up to five (5) years from a deceased...more
On July 8, 2022, the IRS issued Revenue Procedure 2022-32, which provides a simplified method for taxpayers to obtain an extension of time to make a portability election of a deceased spouse’s unused exclusion amount (“DSUE”)...more
The Internal Revenue Service recently issued Rev. Proc. 2022-32 which provides that estates may elect “portability” of a deceased spouse’s unused exclusion (DSUE) up to five years after the decedent’s date of death. ...more
Every U.S. citizen may gift, during life or at death, assets to his or her children free of federal estate or gift tax up to an aggregate amount – frequently called the “exemption amount.” The exemption amount in 2021 is...more
Recently widowed individuals whose deceased spouse’s estate did not make a portability election by the due date for filing an estate tax return -- because the estate either was not aware a portability election was available...more
The Tax Cuts and Jobs Act provides greater flexibility in estate planning for many taxpayers. So, no more estate tax worries for most people, right? Not so fast. For residents of some states, state estate or inheritance taxes...more
Somewhat lost in the clamor of the tax changes enacted by the Tax Cuts and Jobs Act is the fact that the new law preserves the “portability” provision for married couples. Portability allows an estate to elect to permit the...more
In This Issue: - Tax Cuts and Jobs Act supercharges exemption portability - Buy-sell agreements: When a smart business decision also makes estate planning sense - Picking up stakes: Understand the tax and estate...more
On December 22, 2017, President Trump enacted the Tax Cuts and Jobs Act, (“TCJA”) ushering in significant changes to the federal estate, gift and generation-skipping transfer tax laws. Through December 31, 2017, the federal...more
The concept of portability, permanently enacted as part of the amendments to the estate tax law under the American Taxpayer Relief Act of 2012, allows the deceased spousal unused exclusion amount (DSUEA) of a decedent to be...more
Many of you have heard of the new Federal estate tax “portability” rule that allows a surviving spouse to effectively inherit any unused federal estate tax exemption of a predeceased spouse. An individual can only use the...more
The election for married couples to elect portability of the Federal Estate Tax Exemption was introduced in late 2010 when the Tax Relief Unemployment Insurance Reauthorization and Job Creation Act (“TRUIRJCA”) was signed...more
In a long-awaited move, the IRS announced recently that taxpayers will now have at least two years to file an estate tax return to elect portability of a decedent’s unused estate tax exemption to the decedent’s surviving...more
For individuals dying after December 31, 2010, Section 2010(c) of the Internal Revenue Code provides that the unused estate tax exemption of the first deceased spouse is “portable” between spouses at death. Under this law, a...more
Recently, the IRS issued Revenue Procedure 2017-34 (the “Revenue Procedure”), providing a simplified process for certain estates requiring an extension of time to make a portability election under § 2010(c)(5)(A) of the...more
On June 9, 2017, the Internal Revenue Service issued Revenue Procedure 2017-34, which is effective immediately and provides a simplified method to obtain permission for an extension of time under Reg. 301.9100-3 to file Form...more
When the IRS enacted the portability election provisions in 2011, which allowed estates of married taxpayers to pass along the unused part of their estate and gift tax exclusion amount to their surviving spouse, it remarked...more
One of the key changes of the 2010 Tax Relief Act is the addition of “portability” of the first deceased spouse’s unused basic exclusion amount, commonly referred to as the deceased spousal unused exclusion amount. Under...more
December Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The December § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more
2017 Estate, Gift and GST Tax Update: What This Means for Your Current Will, Revocable Trust and Estate Plan - As we previously reported, the American Taxpayer Relief Act of 2012 (the "Act") made the following permanent:...more