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
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
The proposed regulations update outdated references and information under the current regulations, including references to temporary regulations, IRS officials, offices and addresses. The proposed regulations conform with...more
It’s not enough for the founder of a closely held business to have successfully established the business. The business has to grow, not only to increase profits, but also to make it more competitive and to diversify its...more
The Arkansas Uniform Fiduciary Income and Principal Act (the “Act”) became effective on January 1, 2022. Arkansas is one (1) of five (5) states, including Colorado, Kansas, Utah, and Washington, that has enacted the Uniform...more
December Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - Important federal interest rates continue to rise. The December applicable federal rate...more
The Internal Revenue Service recently released IRS Notice 2017-15 to provide special procedures for spouses in a same-sex marriage, or the executor of a same-sex spouse, to recalculate their gift and estate tax applicable...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
The Treasury and the IRS can cross off another project from their joint priority guidance plan. IRS Revenue Procedure 2016-49, effective as of September 27, 2016, settles an issue arising when both QTIP and portability...more
The recent issuance of Rev. Proc. 2016-49, which modifies and supersedes Rev. Proc. 2001-38, now puts the taxpayer in the driver’s seat. Recall that in Rev. Proc. 2001-38, the Service was providing relief for the surviving...more
Action Item: This year, Blank Rome’s annual estate planning newsletter will be issued in six installments. Each installment will discuss certain concepts and techniques that we hope may be of interest to our clients and...more
In a recent taxpayer victory, the Tax Court found in favor of the taxpayer with respect to three hotly contested gift and estate planning issues involving family limited liability companies. The Tax Court decided the case of...more
November Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The November § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more
In this Issue: - March Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra Family Loans and Split Interest Charitable Trust - Estate of Giovacchini v. Commissioner, T.C. Memo 2013-27 - Estate of...more