News & Analysis as of

Trusts Estate Tax Internal Revenue Service

ArentFox Schiff

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

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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

BakerHostetler

[Podcast] Estate and Tax Planning for Globally Mobile Clients: Purchasing U.S. Real Estate by Non-U.S. Persons

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Non-Americans who wish to purchase U.S. real estate should be aware of the tax consequences of owning real estate here. George McCormick discusses these tax issues and steps to minimize their impact....more

Husch Blackwell LLP

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

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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

DarrowEverett LLP

Maximizing QSBS Benefits with Estate Planning: The Art of Stacking

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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

Roetzel & Andress

Now That We’ve Seen the Eclipse, It’s Time To Plan for the TCJA Sunset

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As the ball drops in Times Square on December 31, 2024, many of the tax breaks established by the Tax Cuts and Jobs Act (TCJA) of 2017 will disappear. While the TCJA made some permanent tax cuts, a number of tax cuts and...more

Rivkin Radler LLP

Estate, Gift, GST & Related Income Tax Proposals – What is the White House Doing?

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Earlier this week the White House released its Fiscal Year 2025 Budget. Of course, the federal government has not yet adopted a budget for the Fiscal Year 2024 even as we approach that year’s halfway mark. But I digress. The...more

Keating Muething & Klekamp PLL

Recent IRS Decision Threatens Some Irrevocable Trust Modifications

A recent Chief Counsel Advice issued by the IRS has been described by one team of estate planning experts as “the most important IRS ruling in a decade,” and it directly contradicts the prior IRS position on the issue. Should...more

ArentFox Schiff

What Private Companies Need To Consider in 2024: Top 10 Legal Issues

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Private companies and their owners face ever-evolving challenges as the market sees new regulations, new deal trends, and new risks in 2024. Below are 10 issues that the owners and leaders of privately held companies should...more

Davidoff Hutcher & Citron LLP

If It's Too Good To Be True...The Latest Guidelines from the IRS

There are a lot of very smart tax attorneys out there who are trying to figure out something new, and yet there’s very little innovation.  Almost all techniques that we use are incremental variations of an older technique...more

Rivkin Radler LLP

Taxes and the 2024 Election: ‘Tis the Season to Plan and Act

Rivkin Radler LLP on

This is The End- I have dreaded the year end for as long as I can remember. As a teenager and then as a young adult I associated the final quarter of the year, and especially the period beginning on Thanksgiving and...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

Seyfarth Shaw LLP

Year-End Estate Planning for 2023

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A strong stock market and “soft landing” have generated significant wealth this year. The gift tax, estate tax and generation-skipping transfer tax are all imposed on the fair market value of assets at the time of transfer....more

Allen Barron, Inc.

Tax Tips for Lottery Winners

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Today is the anniversary of the largest Powerball lottery victory in the United States of $2.04 billion.  Just over the $1.765 billion jackpot claimed last month (Oct 2023).  What are some tax tips for lottery winners and...more

Rivkin Radler LLP

Disclaiming to Save Taxes

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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

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

Rivkin Radler LLP

The Federal Attack on Grantor Trusts: The Demise of Basis Step-Up at Death?

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On March 20, 2023, Senators Warren, Sanders, Van Hollen, and Whitehouse addressed a letter to Treasury Secretary Yellen in which they urged Yellen “to use [her] existing authority to limit the ultra-wealthy’s abuse of trusts...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Notwithstanding Savings Clause, Judicial Reformation Required to Correct Defects in Charitable Remainder Annuity Trust

A recent tax court case serves as a stern reminder to practitioners that (1) in order for a trust to qualify as a charitable remainder annuity trust (CRAT), the trust’s governing instrument must unambiguously provide for a...more

Freeman Law

Tax Court in Brief | Estate of Kalikow v. Comm’r | Estate Tax Taxation and Deductions and QTIP Trust

Freeman Law on

Summary: Pearl B. Kalikow’s  (“Pearl”) husband died in 1990.  On January 4, 2006, Pearl passed away. The SK Trust (“Trust”) was created with the remainder of Pearl’s husband’s estate. On Pearl’s husband will it was instructed...more

Katten Muchin Rosenman LLP

2022 Year-End Estate Planning Advisory

During 2022, COVID-19, the war in Ukraine, global inflation, the Tax Cuts and Jobs Act (TCJA), the uncertainty about the Build Back Better Act (BBBA), the Corporate Transparency Act (CTA), and the Inflation Reduction Act...more

Rivkin Radler LLP

Sale to IDGT, Death of Grantor, Basis Step-Up: Treasury’s Priority Guidance & the Dems’ Loss of the House

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Some folks eagerly await the release of a new album. Others camp outside of big box retailers to get the jump on holiday gifts. There are those who line up at box offices to purchase tickets for a concert that is months away....more

Rivkin Radler LLP

Trusts, the Death of a Shareholder, and The S Corporation Election

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The Key Person- The closely held corporation is often a fragile creature. Too often, its continued success and well-being are overly dependent upon the continued involvement of one individual – namely, the founder and...more

Woods Rogers

‘Tis the Season (For Charitable Giving)

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The year-end is approaching, but you still have time to work on your 2022 tax planning. Consider giving to your favorite charity to make this holiday season merry. Planned charitable giving provides you a way to maximize...more

Shumaker, Loop & Kendrick, LLP

The Estate Planner, November/December 2022

Rising rates spark interest in charitable remainder trusts - If you wish to leave a charitable legacy while generating income during your lifetime, a charitable remainder trust (CRT) may be a viable solution. In addition...more

Holland & Knight LLP

Planning for the Future: Estate and Tax Planning with Digital Assets

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Cryptocurrencies are becoming a larger component of investors' portfolios, especially for millennials and Generation Z, who collectively make up 94 percent of cryptocurrency buyers. While it may seemingly be too early for...more

Blank Rome LLP

2022 California Estate and Tax Planning Newsletter

Blank Rome LLP on

Our annual estate and tax planning newsletter discusses certain concepts and techniques that should be considered in 2022 by our clients and friends in California. Perhaps the most important recent development was the failure...more

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