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It is not uncommon for family members to lend a helping hand to one another through intrafamily loans. While loans can benefit family borrowers who may not qualify for a traditional loan or who need flexible payment...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
A recent Tax Court order highlights the gift and estate planning opportunities afforded when a senior family member makes loans to other family members. In Galli v. Commissioner, Docket Nos. 7003-20 and 7005-20, the Court had...more
A parent will sometimes transfer money to a child to enable the child to make an investment that the child could not otherwise make on their own. For example, the child may have identified an attractive business opportunity...more
March 2025 AFRs and 7520 Rate - The March 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.40%, which was the same as the February 2025 rate...more
The case of Salus Mundi Foundation et al v. Commissioner - On August 15, 2016, the Tax Court decided in Salus Mundi Foundation et al v. Commissioner, T.C. Memo. 2016-154, that two foundations were liable as transferees...more