Once Removed Episode 18: The Reciprocal Trust Doctrine
A large part of business sucession planning is structuring the transfer of business ownership. While outright transfers can be less complex, transferring ownership in trust can provide practical benefits that are worth...more
Business succession planning and estate planning are often linked together, particularly in the case of closely held family businesses. In the case of a shareholder who wishes to pass along their shares of an S corporation as...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
The April 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.00%, which is 0.40% less than the March 2025 rate. The April applicable federal rate (“AFR”) for use with a...more
February 2025 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The February applicable federal rate (“AFR”) for use with a sale to a defective grantor...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
Trusts are described in multiple ways, including: living or testamentary, revocable or irrevocable and grantor or non-grantor. These terms are not always mutually exclusive. A trust can be living, revocable and a grantor...more
A trust structure, commonly used for estate planning, can be problematic in certain civil law jurisdictions, such as those in many European countries. Recent acts enacted in Wyoming and New Hampshire allow for the...more
Grantor trusts allow for tax deductions on income generated by trust assets whereas non-grantor trusts do not allow for these deductions. It is crucial for people to carefully decide which type of trust is best for their...more
According to a report issued by the National Association of Realtors a couple of days ago, last year saw a large outmigration of people from California and New York, while Florida and Texas experienced a comparably large...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
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
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
On Sunday, September 12, 2021, the House Ways & Means Committee (the "Committee") released draft legislation as part of Congress' ongoing $3.5 trillion budget reconciliation process. The legislation, as approved by the...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
- 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
Creating an education legacy - For many people, an important goal of estate planning is to leave a legacy for their children, grandchildren and future generations. And what better way to do that than to help provide for...more
In a previous newsletter, we recently heralded the passage of the “Connecticut Qualified Dispositions in Trust Act”, which permits the creation and establishment of self-settled domestic asset protection trusts (“DAPTs”). To...more
April Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The April § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and...more
Corporate attorneys usually think of trusts as estate planning tools: they are the vehicles through which the owner of a business may pass along to their family a beneficial interest in the business without actually giving...more
Powers of attorney and trust instruments have each been the subject of many an estate plan. They each have also been the subject of multiple estate litigations. In combination, the two have served as fodder for controversies...more
Income Tax Considerations of Estate Planning Are More Important Than Ever - Gifting assets during life will reduce the size of your taxable estate at death and, correspondingly, reduce your estate tax liability. But with...more
In March, the Department of Treasury issued the administration's 2015 fiscal year revenue proposals for the federal government. Those proposals are described in General Explanations of the Administration's Fiscal Year 2015...more
March Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts The March § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and...more
It’s no secret that the cost of a college education continues to soar. But this article offers three options to help one’s grandchildren deal with this burden while saving gift and estate taxes: direct tuition payments to the...more