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
“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
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 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
- 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