The Internal Revenue Service (IRS) recently issued Private Letter Ruling (PLR) 202504006, addressing several important estate and gift tax questions related to the division of a marital trust and the subsequent disclaimer of...more
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
Massachusetts is already an unattractive state of residency from an estate tax planning perspective because of its low estate tax filing threshold of $1,000,000 per person. Once a person’s adjusted taxable estate is over $1M...more
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
Retroactivity is an endemic problem in the state tax world. In this year alone, we have seen retroactive repeal of the Multistate Tax Compact (MTC) in Michigan, as well as significant retroactivity issues in New York, New...more