News & Analysis as of

Irrevocable Trusts Estate Tax Internal Revenue Service

Hughes Hubbard & Reed LLP

Trump Law’s Estate Tax Exemption Is a Boon for Wealth Planning

President Donald Trump’s massive tax-and-spending package requires attention from both individuals and estate planners to advance their estate and income tax planning objectives. Originally Published by Bloomberg Law. ...more

Kohrman Jackson & Krantz LLP

Act Now or Pay Later? Estate Planning Strategies Before the 2025 Tax Sunset

The current federal estate tax exemption levels, introduced by the Tax Cuts and Jobs Act (TCJA) in 2018, have provided historically high federal estate tax exemptions. But this period of increased exemption is expected to...more

Strafford

[Webinar] New IRS Guidance on Basis Adjustments for Irrevocable Grantor Trusts: Key Issues for U.S. and Non-U.S. Persons - June...

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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

Blank Rome LLP

Is CCA 202352018 the Death of Irrevocable Trust Decantings?

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For years, practitioners have freely used irrevocable trust decantings as a means to make various changes to irrevocable trusts without concern of giving rise to gift tax consequences. However, the Internal Revenue Service’s...more

Rivkin Radler LLP

Disclaiming to Save Taxes

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It’s not enough for the founder of a closely held business to have successfully established the business. The business has to grow, not only to increase profits, but also to make it more competitive and to diversify its...more

Blank Rome LLP

IRS Disallows Step-Up in Tax Cost Basis for Assets Held by an Irrevocable Grantor Trust

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Under current law, assets acquired from a decedent receive an adjustment in cost basis to fair market value, thereby potentially eliminating significant unrealized gain. Although Congress has and likely will use this tax...more

Cole Schotz

IRS Issues Revenue Ruling Holding that Assets Held in an Irrevocable Grantor Do Not Receive a Step-Up in Basin at Death

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In a recently-issued Revenue Ruling (Rev Rul 2023-02), the IRS has held that the basis of the assets in an irrevocable grantor trust, where the assets are not included in the grantor’s gross estate for federal estate tax...more

Proskauer Rose LLP

Wealth Management Update - April 2023

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The April Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.0%. The April applicable federal rate (“AFR”) for use with a sale to a defective grantor trust or intra-family loan...more

Rivkin Radler LLP

The Federal Attack on Grantor Trusts: The Demise of Basis Step-Up at Death?

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On March 20, 2023, Senators Warren, Sanders, Van Hollen, and Whitehouse addressed a letter to Treasury Secretary Yellen in which they urged Yellen “to use [her] existing authority to limit the ultra-wealthy’s abuse of trusts...more

Polsinelli

Estate Planning During Periods of Inflation and Market Volatility

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Earlier this year the stock market entered bear market territory.  This happens when the market declines more than 20% or more from its most recent high.  The market decline has been attributed to several factors including...more

Freeman Law

Tax Court in Brief | Estate of Levine v. Commissioner | Split-Dollar Life Insurance and Estate Planning

Freeman Law on

Tax Litigation:  The Week of February 28, 2022, through March 4, 2022 - Shaddix v. Comm’r | TC Memo. 2022-11 | February 28, 2022 | Lauber, J. | Dkt No. 12683-20L - Estate of Kazmi v. Comm’r, T.C. Memo. 2022-13| March 1,...more

Rivkin Radler LLP

Gifts, Sales and Effective Dates: The Race Against the Clock the Taxpayer Cannot See

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It was quite a week, wasn’t it?- Manchin- Senator Manchin continued to attract a lot of attention. To the dismay of his fellow Democrats, the West Virginian – who also chairs the Senate Energy and Natural Resources...more

White and Williams LLP

Estate Planning Toolbox: Spousal Lifetime Access Trust (SLAT)

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Transfers of appreciating assets to spousal lifetime access trusts (SLATs) have become an increasingly popular and flexible estate planning technique. By making a completed gift now, a donor can lock in gifts of amounts up to...more

Genova Burns LLC

IRS Rules Gift Splitting Differs for Gift and GST Tax Purposes

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In PLR 201811002 the IRS has ruled that gift splitting works differently when applied to Gift taxes and Generation Skipping Transfer (GST) taxes. Gift splitting is authorized by IRC Section 2513(a)(1) and states, generally,...more

Proskauer Rose LLP

Wealth Management Update - December 2016

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December Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The December § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more

Proskauer Rose LLP

Personal Planning Strategies - December 2016

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2017 Estate, Gift and GST Tax Update: What This Means for Your Current Will, Revocable Trust and Estate Plan - As we previously reported, the American Taxpayer Relief Act of 2012 (the "Act") made the following permanent:...more

Katten Muchin Rosenman LLP

2016 Year-End Estate Planning Advisory

In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more

Proskauer Rose LLP

Wealth Management Update - February 2016

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February Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The February § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more

Proskauer Rose LLP

Wealth Management Update - October 2015

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October Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The October § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more

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