Across all industries, family offices and their owners and management teams face rapidly evolving challenges, opportunities, and risks in the dynamic environment that is 2025. Here are six issues that family offices should...more
3/14/2025
/ Business Succession ,
Buy-Sell Agreements ,
Corporate Transparency Act ,
Estate Tax ,
Ethics ,
Family Offices ,
FinCEN ,
Generation-Skipping Transfer ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Limited Partnerships ,
Tax Planning ,
Tax Reform ,
Trusts ,
Valuation
The term “resident” is defined differently for US federal income tax purposes and US federal estate and gift tax purposes. The mismatch in the US resident status under the two tax regimes often gives rise to problems. Thus,...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
12/4/2024
/ Estate Planning ,
Estate Tax ,
Gift Tax ,
Internal Revenue Code (IRC) ,
IRS ,
QTIP Trusts ,
Surviving Spouse ,
Tax Court ,
Termination ,
Transfer of Assets ,
Treasury Regulations ,
Trust Distributions ,
Trusts
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
9/18/2024
/ Estate Tax ,
Generation-Skipping Transfer ,
Gift Tax ,
Grantor Retained Annuity Trusts (GRATs) ,
Inflation Adjustments ,
Internal Revenue Code (IRC) ,
IRS ,
Spousal Lifetime Access Trust (SLAT) ,
Sunset Provisions ,
Tax Cuts and Jobs Act ,
Transfer Taxes ,
Trusts
In Connelly v. US, 602 US ___ (6/6/2024), the US Supreme Court affirmed a decision of the US Court of Appeals for the Eighth Circuit in favor of the government concerning the estate tax treatment of life insurance proceeds...more
6/18/2024
/ Business Succession ,
Buy-Sell Agreements ,
Closely Held Businesses ,
Connelly v United States ,
Estate Planning ,
Estate Tax ,
Fair Market Value ,
Internal Revenue Code (IRC) ,
IRS ,
Life Insurance ,
Redemption Agreement ,
SCOTUS ,
Shareholders ,
Small Business ,
Survivorship
The Internal Revenue Service recently issued Notice 2022-53, which provides much needed transition relief in the form of an IRS waiver of the 50% excise tax that could otherwise be imposed upon certain beneficiaries of...more