Once Removed Episode 18: The Reciprocal Trust Doctrine
Every conveyance of property or of an interest in property from one person to another is prompted, or at least influenced, by economic considerations. The parties to the transaction may swap properties, or one party may...more
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
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
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
“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
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
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
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
Where Are We? Have you seen the Triumvirate of late? No, not Julius, Pompey, and Crassus. I’m referring to more contemporary political figures, whose names and exploits are not likely to appear in volumes that will be...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
It is said that two things are certain in life: death and taxes. True, but incomplete. What is missing from this short list is a third inevitable occurrence – tax law changes. We now have a new and pressing series of proposed...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
The Democrats of the House of Representatives have released a much-anticipated tax plan that would significantly impact the federal estate and gift tax system. Importantly, the House could still amend this legislation and the...more
On September 13, the House Ways & Means Committee proposed new tax provisions as part of the Build Back Better Act. The proposal includes many substantial tax changes that would affect personal income tax and business tax...more
Key points •On Wednesday, September 15, The House Ways and Means Committee advanced a proposal for a $2.1 trillion tax increase. •The proposal could drastically change the gift and estate tax treatment of new...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
On Monday, September 13, 2021, the House Ways & Means Committee released a draft tax plan which provides the clearest direction to date on how Democrats intend to use the estate and gift tax regimes to pay for part of the...more
“President Biden and Democrats in the Congress have been working on a $3.5 trillion spending and tax package, and the details are starting to be revealed. Indeed, on Sunday, September 12th, the House Ways and Means Committee...more
House Democrats recently released additional legislative proposals that, if passed, would affect several commonly used estate planning techniques. Among those proposals are three that would significantly impact some of the...more