Once Removed Episode 18: The Reciprocal Trust Doctrine
C Corp - Imagine a closely held and growing start-up business (“Corp”) that was recently incorporated under state law and, so, is treated as a regular C corporation for purposes of the federal income tax. Thus, Corp will pay...more
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
Although the IRS is now on high alert for wealthy individuals, new and existing planning opportunities are available, such as tax-free gifts and other advantageous planning. Wealthy individuals and families should take...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
As 2022 comes to a close, it is worth taking note of the current state of the legislative landscape that could affect estate planning opportunities in the coming year. This year, the Inflation Reduction Act was enacted into...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
Last month, the House Ways & Means Committee (the "Committee") approved draft legislation (the “Legislation”) as part of Congress' ongoing $3.5 trillion budget reconciliation process. The Legislation includes significant tax...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
First Step- Last Wednesday, the House Ways and Means Committee approved that portion of the 2022 budget legislation with which it was tasked by the Congressional Budget resolution of August 24. The text of the bill...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