Once Removed Episode 19: The Step-Transaction Doctrine and the Case of Smaldino
Once Removed Episode 18: The Reciprocal Trust Doctrine
Once Removed Episode 16: Gift and Estate Tax, Inflation Adjustments for 2024
Once Removed Episode 17: Annual Gifting to Individuals: Options, Opportunities and Pitfalls
To Give or Not to Give: Considerations for Year-End Gifting
Across all industries, private companies, family offices, and their owners and management teams face rapidly evolving challenges, opportunities, and risks in the dynamic environment that is 2025. Here are 11 issues that...more
The Gift and Estate Tax Exclusion is currently scheduled to be reduced by approximately 50% in about 13 months. Without action from Congress, on January 1, 2026, the Exclusion will go from almost $14 million to about $7...more
This year was busy for trusts and estates practitioners. With 2025 marking the final year of the Tax Cuts and Jobs Act (TCJA), many of its implications for federal corporate and individual income tax, gift, estate and...more
With the looming elections, tax planners have taken time to consider what the future of Estate and Gift Tax planning might be under the new Congress. Every new Congress considers changes to the Internal Revenue Code of 1986,...more
As we will see shortly, it is often “better to give than to receive,” though this statement begs the obvious question of whether it is better to do so during one’s lifetime or upon one’s death. Many well-to-do individuals...more
The Tax Cuts and Jobs Act (TCJA) of 2017 nearly doubled the federal lifetime gift and estate tax exemption. In 2024, this act currently allows individuals to transfer up to $13.61 million per person and $27.22 million per...more
The Tax Cuts and Jobs Act of 2017 (TCJA) enacted significant changes in the federal estate and gift tax laws commencing in 2018. One of the most notable changes was that the TCJA doubled the federal lifetime gift tax...more
Understanding the nuances of the Internal Revenue Code (I.R.C.) is crucial for effective estate planning and tax strategy. For example, estate planners must be familiar with the tax basis adjustment provisions in 26 U.S.C. §...more
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
In a significant legislative shift, the Tax Cuts and Jobs Act of 2017 doubled the exemption amounts for estate, gift, and generation-skipping transfer taxes (collectively known as “Death Taxes”). As of 2024, the federal...more
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
Current tax laws provide historically high exclusion amounts for the federal estate and generation skipping transfer tax. These exclusion amounts, however, are slated to sunset by roughly 50% at the end of 2025. ...more
Estate planning is a lot like putting together a puzzle. The client provides you with their box lid showing what they want the ultimate result of their plan to look like. Then, estate planners are tasked to identify and...more
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
The Tax Cuts and Jobs Act of 2017 increased the federal estate and gift tax exclusion amount (sometimes called the “basic exclusion amount” or “BEA”) from $5 million to $10 million. (Those numbers are adjusted for...more
The IRS recently released proposed clawback regulations on the treatment of gifts that are complete at the time of transfer but are potentially included in the donor's gross estate at death. Such gifts will likely get the...more
The Treasury Department issued proposed regulations on Tuesday, April 26, 2022 in follow up to the anti-clawback regulations published on November 26, 2019. The 2019 anti-clawback regulations were in response to the Tax Cuts...more
Overview During 2021, COVID-19, the new Biden administration, the Tax Cuts and Jobs Act (TCJA), the Coronavirus Aid, Relief and Economic Security Act (CARES ACT), the American Rescue Plan (ARP), and the uncertainty about the...more
In 2020, COVID-19, the US presidential election, the Tax Cuts and Jobs Act (the TCJA), and the Coronavirus Aid, Relief and Economic Security Act (the CARES ACT) dominated the planning landscape....more
On Tuesday, November 3rd, Americans went to the polls and cast votes for President, Senators, and House members. In some cases, the results are still being tabulated (or subject to challenge). However, the picture becomes a...more
In December 2017, President Trump signed the Tax Cuts and Jobs Act (“TCJA”) into law. As a result, the lifetime gifting and estate tax exemption (“Estate Tax Exemption”), as well as the generation-skipping transfer tax...more
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
For those of sufficient wealth to be concerned about federal estate taxes, lifetime gift giving can be an effective strategy. Although the estate tax is imposed on the aggregate of the taxable estate and lifetime taxable...more
What’s a clawback ? and should you be worried about it? By temporarily doubling the gift and estate tax exemption amount, the Tax Cuts and Jobs Act created an historic opportunity for affluent families to shelter wealth...more
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