Once Removed Episode 18: The Reciprocal Trust Doctrine
In general, stock must be acquired at "original issuance" from the corporation in order to qualify for qualified small business stock (QSBS) treatment under Internal Revenue Code (IRC) Section 1202. As discussed in a previous...more
Earlier this week, California Gov. Gavin Newsom signed into law a retroactive tax on so-called “INGs” — Incomplete Gift Non-Grantor Trusts. Note that the law, which is retroactive to Jan. 1, 2023, has some limitations in...more
On March 28, 2022, President Biden announced his 2023 federal budget (Budget), which is often referred to as the President’s Green Book. While much of the Budget harkens back to the “Build Back Better Framework” (Framework),...more
“Déjà vu All Over Again”- The White House last week released the President’s Budget for the Fiscal Year 2023. The Budget is ambitious, but its “investments,” we are told, “are more than paid for with tax reforms focused on...more
Plan focuses on eliminating certain available estate planning opportunities and increasing rates for corporations and high net worth individuals. The proposed tax plan from House Ways and Means Committee seeks to eliminate...more
In this second blog post on the House Ways and Means Tax proposals, we address the proposed changes that will affect the taxation of trusts, estates, and retirement plans. As we discussed, on September 13, 2021, the...more
The House of Representatives Ways and Means Committee Chairman introduced new tax proposals on Monday that would raise more than $2 trillion in tax revenue as part of the Democrats’ effort to roll back the Trump...more
The House of Representatives Joint Committee on Taxation released its highly anticipated synopsis of the colloquial “tax bill.” Bill JCX-43-21 is the latest piece of legislation in a flurry of recent legislative activity...more
July 2021 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts AFRs - The July applicable federal rate ("AFR") for use with a sale to a defective grantor...more
As a result of Governor Jay Inslee signing S.B. 5096 on May 4, 2021, Washington state will begin imposing a 7 percent tax on certain long-term capital gains beginning January 1, 2022. For a detailed overview of the new law,...more
- Annual inflation-indexing continues to increase the historically high lifetime exemption amount for gift, estate, and generation-skipping transfer taxes. Those of considerable wealth who have not yet made gifts, such as...more