News & Analysis as of

U.S. Treasury Estate Planning

Perkins Coie

Treasury Releases First Installment of Long-Awaited Guidance on Donor-Advised Funds

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Over the past several years, the U.S. Department of the Treasury has been preparing guidance concerning donor-advised funds (DAFs), which are accounts owned and controlled by public charities over which individual or...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

Pillsbury Winthrop Shaw Pittman LLP

Estate and Tax Planning 2023 Update: Act While You Can

Although the IRS is now on high alert for wealthy individuals, new and existing planning opportunities are available, such as tax-free gifts and other advantageous planning. Wealthy individuals and families should take...more

Keating Muething & Klekamp PLL

Estate Planning Update: Preparing for the Corporate Transparency Act

Effective January 1, 2024, a sweeping anti-financial crimes law – the Corporate Transparency Act – will affect every small business. If you own an interest in a small business, even a single-member LLC, you may be subject to...more

McDermott Will & Emery

Highlights from the Final Opportunity Zone Regulations

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The US Treasury released Final Regulations providing guidance under Subchapter Z (the Opportunity Zone Provisions) of the Internal Revenue Code in December of 2019. The Final Regulations clarify many portions of two earlier...more

BCLP

IRS Issues Final Regulations Quashing Taxpayer Fears of Clawback on Gifts

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The Treasury Department issued final regulations, citing the Tax Cuts and Jobs Act (TCJA), on  November 26, 2019 (Treasury Decision 9884) confirming that taxpayers will not be subject to “clawback” of the value of their...more

Cozen O'Connor

Tax Update: The Impact of Newly Published Regulations on the Estate and Gift Tax Laws

Cozen O'Connor on

In November 2019, almost two years after the enactment of the comprehensive overhaul of the Internal Revenue Code, the Department of the Treasury published regulations to clarify the impact of the new law on the estate and...more

Stinson LLP

IRS Eliminates Worry About "Clawback"

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In response to Internal Revenue Code Section 2001(g)(2), enacted as part of the 2017 Tax Act, in which the Secretary of the Treasury was directed to prescribe regulations to carry out IRC Section 2001(g) with respect to the...more

Holland & Hart LLP

New IRS Addresses for Filing Estate Tax Returns

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The Instructions for Form 706 released in November 2018 included new addresses; however, we felt a reminder could be useful since the filing address changed mid-year...more

Bradley Arant Boult Cummings LLP

Proposed Tax Regulations Eliminate Possibility of Clawback of Lifetime Gifts for Estate Tax Purposes

As previously posted, the Tax Cuts and Jobs Act signed into law in December 2017 (the “2017 Act”) made significant changes to the federal wealth transfer system with respect to gift and estate tax transfers during the...more

Proskauer Rose LLP

Wealth Management Update - December 2018

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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

Proskauer Rose LLP

Personal Planning Strategies - December 2018

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Estate, Gift and GST Tax Update - What This Means for Your Current Will, Revocable Trust and Estate Plan - The estate and gift tax regimes have been permanent and unified since the passage of The American Taxpayer...more

McGuireWoods LLP

IRS to Issue Regulations on Effect of Section 67(g) on Certain Deductions for Estates and Nongrantor Trusts

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The U.S. Treasury Department and the IRS announced on Friday, July 13, 2018, that they intend to issue regulations on the impact of new section 67(g) of the Internal Revenue Code of 1986 on certain deductions for estates and...more

Butler Snow LLP

Proposed Section 2704 Regulations to be Withdrawn

Butler Snow LLP on

Remember all that time and energy you put into figuring out what the proposed regulations under Section 2704 were all about? Well, you’re going to want to try to find a way to get that back. The proposed regulations, the...more

Tucker Arensberg, P.C.

IRS and Treasury Department Announce Withdrawal of Proposed 2704 Regulations

Tucker Arensberg, P.C. on

On October 4, 2017, in its Second Report to the President Identifying and Reducing Tax Regulatory Burdens the U.S. Department of the Treasury announced that it is recommending the complete withdrawal of the proposed 2704...more

Lowndes

Treasury Plans to Pull Unpopular Discount Regulation

Lowndes on

As discussed earlier this summer, Treasury and the IRS identified as a burdensome regulation the Proposed Regulations under Section 2704 of the Internal Revenue Code, which regulations would severely impact discounts on gifts...more

Lowndes

Treasury Plans to Pull Unpopular Discount Regulation

Lowndes on

As discussed earlier this summer, Treasury and the IRS identified as a burdensome regulation the Proposed Regulations under Section 2704 of the Internal Revenue Code, which regulations would severely impact discounts on gifts...more

Perkins Coie

Quarterly Investment Update - 4th Quarter 2016

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ECONOMIC REVIEW AND OUTLOOK - In this past year we were reminded again to expect the unexpected: The well-established political classes in the U.K., the U.S. and Italy learned that democracy was their Achilles’ heel, and...more

Bradley Arant Boult Cummings LLP

Proposed Tax Regulations Limit Availability of Valuation Discounts to Family Business Owners

For family business owners who desire to transfer ownership of part of their business to the next generation, the valuation of the business interest is often an important factor to consider. This is especially true for family...more

Burr & Forman

IRS Proposes New Rules Designed to Restrict Valuation Discounts in Family Transfers

Burr & Forman on

Partnerships and LLCs are common choices of entity for family-owned businesses, due to their flexibility and the many uses to which they can be put – including pooling of family assets, succession planning, asset protection,...more

Akin Gump Strauss Hauer & Feld LLP

IRS Proposes Regulations to Limit Valuation Discounts for Family Businesses

On August 2, 2016, the Internal Revenue Service and the Treasury Department issued proposed regulations intended to substantially limit the use of discounts in valuing intra-family transfers of interests in family-controlled...more

Tucker Arensberg, P.C.

Proposed 2704 Regulations: Significant Impact on Valuation Discounts for Family Businesses

Tucker Arensberg, P.C. on

Background: On August 4, 2016, the Treasury Department and Internal Revenue Service issued proposed regulations addressing the valuation of certain business interests for federal estate, gift and generation-skipping tax...more

Dechert LLP

Proposed Treasury Regulations Regarding Valuation Discounts for Transfers of Family-Controlled Entities, if Enacted, Would Apply...

Dechert LLP on

After years of anticipation, the U.S. IRS recently issued Proposed Treasury Regulations that would, if enacted in their current form, substantially eliminate most valuation discounts for family-controlled entities and result...more

Ward and Smith, P.A.

The End of Family Business Valuation Discounts?

Ward and Smith, P.A. on

Proposed Treasury Regulations Prompt Immediate Action - The Threat to Planning with Family Business Interests: Recently proposed regulations threaten a powerful planning technique – the use of valuation discounts...more

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