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
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
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
- 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