Strategy Considerations for Global Litigation
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
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
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
In 2009, each individual had a $3.5 million estate tax exemption. If a married individual had assets over $3.5 million, without careful planning, those assets in excess of $3.5 million would fall subject to a 45% estate tax....more