News & Analysis as of

Internal Revenue Service Grantor Trusts Estate Planning

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
DarrowEverett LLP

Business Succession Planning: Pros and Cons of Passing S Corp Shares in Trust

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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

Proskauer Rose LLP

Wealth Management Update - February 2025

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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

Rivkin Radler LLP

Thinking About Making Taxable Gifts Before the 2026 Sunset?

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As we will see shortly, it is often “better to give than to receive,” though this statement begs the obvious question of whether it is better to do so during one’s lifetime or upon one’s death. Many well-to-do individuals...more

Proskauer Rose LLP

Wealth Management Update - September 2024 - 2

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September 2024 AFRs and 7520 Rate - The September 2024 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 4.8%, a decrease from the August 2024 rate of 5.2%. The September...more

Husch Blackwell LLP

Understanding the 2026 Changes to the Estate, Gift, and Generation-Skipping Tax Exemptions

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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

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

Bilzin Sumberg

Take Care When Utilizing Tax Reimbursement Clauses in Trusts…Even If You Are a Cross-Border Practitioner

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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

Pillsbury Winthrop Shaw Pittman LLP

Estate and Tax Planning 2023 Update: Act While You Can

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

Proskauer Rose LLP

Wealth Management Update - June 2023

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June 2023 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split-Interest Charitable Trusts - The June Section 7520 rate for use in estate planning techniques such as CRTs, CLTs, QPRTs...more

Proskauer Rose LLP

Wealth Management Update - May 2023

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May 2023 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split-Interest Charitable Trusts - The May Section 7520 rate for use in estate planning techniques such as CRTs, CLTs, QPRTs and...more

Freeman Law

The IRS and Abusive Trust Arrangements: Non-Grantor Trusts

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Under federal tax law, there are significant differences between grantor and non-grantor trusts. Grantor trusts are treated as disregarded entities.  In layman’s terms, this means that the grantor (i.e., the creator or the...more

Freeman Law

Why You Should Hire a Tax Professional to Review Your Trust

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Trusts come in many variations, rendering them often difficult for non-attorneys to follow and comprehend.  Indeed, this variation can often be seen in the nomenclature used for trust arrangements, which includes terms such...more

Proskauer Rose LLP

Wealth Management Update - June 2022

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The June Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 3.6%, an increase from the May rate of 3.0%. The June applicable federal rate (“AFR”) for use with a sale to a...more

Freeman Law

The IRS’s Renewed Focus on Abusive Trust Arrangements

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Taxpayers have long utilized trust arrangements for the transfer of wealth to beneficiaries or for the protection of assets from creditors.  Generally, there is nothing nefarious about these types of arrangements.  Rather,...more

Rivkin Radler LLP

Gifting Business Interests Before Selling the Business? Think Valuation

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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

Proskauer Rose LLP

Personal Planning Strategies - October 2021

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Act Now Before the Window of Opportunity Closes - By now you have probably heard that the House Ways and Means Committee introduced legislation a few weeks ago (see Let the Estate Tax Planning Games Begin - But Where Will...more

Akerman LLP

Draft Legislation in U.S. House of Representatives Would Dramatically Alter Estate Planning Strategies

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On September 10, 2021, the U.S. House Committee on Ways and Means released a draft of proposed legislation that, if enacted into law, would reduce the estate tax exemption and significantly limit the effectiveness of certain...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposals for Trusts, Estates, and Retirement Accounts

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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

Proskauer Rose LLP

Let the Estate Tax Planning Games Begin - But Where Will They Land - the House Ways and Committee Has Spoken

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“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

Proskauer Rose LLP

Wealth Management Update - January 2021

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January 2021 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - Certain federal interest rates increased slightly for January of 2021 while others...more

Proskauer Rose LLP

Wealth Management Update - December 2020

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December 2020 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts AFRs - Certain federal interest rates increased slightly for December of 2020, while...more

Proskauer Rose LLP

Personal Planning Strategies - October 2020

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Top Ten Estate Planning Recommendations before the End of 2020 - If you have not already been inundated with invitations to webinars, articles and newsletters regarding the estate planning you should consider doing before...more

Proskauer Rose LLP

Wealth Management Update - October 2020

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Important federal interest rates continue to hold relatively steady. The October Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 0.4%, which is unchanged from a month ago....more

Proskauer Rose LLP

Wealth Management Update - July 2020

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July 2020 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intrafamily Loans and Split-Interest Charitable Trusts - The July Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more

Lathrop GPM

Legacy & Tax Planning in a Pandemic

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A confluence of events has created an uncommon opportunity to transfer wealth and support charity: financial markets have declined because of the COVID-19 pandemic; in response, the Coronavirus Aid, Relief, and Economic...more

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