Once Removed Episode 18: The Reciprocal Trust Doctrine
The May 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.00%, which is the same as the April 2025 Section 7520 rate...more
As 2024 quickly comes to a close, the new year will bring a change in the presidency, a new Congress, and potential changes to policies and laws that could impact individuals of all wealth levels. Going into the election,...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
Financial markets, political moods, and the world-at-large can take us on a roller coaster ride of ups and downs. But savvy investors (and their estate planning counsel) know that – in the end – neither the bears nor bulls...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
This CLE/CPE webinar will provide estate planners insight on recently issued IRS guidance regarding basis adjustments for irrevocable grantor trusts. The panelist will discuss key items and challenges stemming from Revenue...more
This podcast often discusses the elements of a trust, and how to grant access, control and flexibility to beneficiaries and trustees. But for tax and other purposes, the donor typically cannot retain those kinds of powers. ...more
Until recently, there was a fair amount of comfort amongst practitioners that, when structured correctly, utilizing a tax reimbursement clause for a grantor trust did not produce any negative U.S. gift or estate tax results....more
Trusts come in many variations, rendering them often difficult for non-attorneys to follow and comprehend. Indeed, this variation can often be seen in the nomenclature used for trust arrangements, which includes terms such...more
Leveraging QPRTs in a High Interest Rate Environment - A Qualified Personal Residence Trust, or “QPRT” is a planning strategy specifically authorized in the Internal Revenue Code that allows an individual to remove a...more
The June Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 3.6%, an increase from the May rate of 3.0%. The June applicable federal rate (“AFR”) for use with a sale to a...more
You likely are aware, from the news and our prior communications, that Congress currently is considering proposals that may have a significant impact on many estate plans. Although we still cannot be certain which, if any, of...more
Counting the Days?- We are 302 days away from the national mid-term elections, to be held November 8, 2022, yet the first full week of the new year has already highlighted some of the economic issues with which the...more
Federal interest rates increased slightly for November of 2021. The November applicable federal rate ("AFR") for use with a sale to a defective grantor trust, self-canceling installment note ("SCIN") or intra-family loan with...more
Certain revenue-raising proposals that would have affected the transfer tax regime and estate planning of high-net-worth individuals and trusts, which were included in the prior proposed bill in the House of Representatives,...more
What You Should Know •The House Ways and Means Committee has approved the tax provisions of President Biden’s Build Back Better Act, a significant first step towards passage. •If passed as drafted, the proposed...more
On September 13, the House Ways and Means Committee released a proposed plan to pay for the $3.5 trillion Build Back Better Act (the “Act”). The proposed legislation contains a variety of changes across the tax code, but the...more
The U.S. House Committee on Ways and Means’ tax proposals would significantly impact estate planning for high net worth individuals if enacted. Gift, estate and GST exemption amounts would be decreased; grantor trusts would...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
What you need to know: On September 13, 2021, the House Ways and Means Committee released its proposed tax plan to fund President Biden’s $3.5 trillion “Build Back Better” social and economic spending package. If enacted as...more
Last week the House Ways and Means Committee released a draft of proposed tax law changes to include in a reconciliation bill. While it is uncertain whether any of these proposals will be adopted – and if so in what form –...more
As many people are aware, Congress is considering changes to the federal tax code to support President Biden’s Build Back Better spending plan. As of this writing, on September 22, 2021, no bill has been enacted....more
Last week, the House Ways and Means Committee released proposed legislation affecting numerous transfer and income tax provisions of the Code. These changes, if enacted, will have a significant impact on estate planning and...more
You have probably heard that the House Ways and Means Committee released proposals for increasing gift and estate taxes in order support legislation being advanced by the Democratic majority in Congress. ...more
Last week, the House Ways and Means Committee released, and advanced out of committee, draft tax legislation intended to form a part of the Democratic budget reconciliation bill. At almost 900 pages in length, this draft...more