News & Analysis as of

U.S. Treasury Estate Tax

Procopio, Cory, Hargreaves & Savitch LLP

Elementos clave de la “One Big Beautiful Bill”

La Cámara de Representantes de los EE.UU. aprobó hoy, con una votación de 218 a favor y 214 en contra, la versión previamente autorizada por el Senado del proyecto de ley conocido como “One Big Beautiful Bill”. Se espera que...more

Ropes & Gray LLP

2025 Tax Legislation Update: One Big Beautiful Bill Act Narrowly Passes Senate

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The “One Big Beautiful Bill Act” (the “BBB”) was passed by the U.S. House of Representatives on May 22, 2025 (such version, the “House Bill”) as part of the Republican Congress’s reconciliation package. The BBB generally...more

Rivkin Radler LLP

The Limited Partner Exclusion From Self-Employment Tax – But Who Is A Limited Partner?

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An Agency Under Siege - The mission statement of the IRS reminds taxpayers that it is their responsibility to understand and meet their tax obligations, while it is the role of the IRS to “enforce the [tax] law with...more

Proskauer Rose LLP

Personal Planning Strategies - November 2024

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What This Means for Your Current Will, Revocable Trust and Estate Plan - The estate and gift tax regimes have been permanent and unified since the passage of The American Taxpayer Relief Act of 2012 (the "2012 Act"). In...more

Rivkin Radler LLP

Estate, Gift, GST & Related Income Tax Proposals – What is the White House Doing?

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Earlier this week the White House released its Fiscal Year 2025 Budget. Of course, the federal government has not yet adopted a budget for the Fiscal Year 2024 even as we approach that year’s halfway mark. But I digress. The...more

McDermott Will & Emery

West Coast Forum 2023 | Key Takeaways

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McDermott’s Private Client Practice led interactive discussions on a broad range of topics pertinent to ultra-high-net-worth families, their family office representatives and other advisors at our Private Client West Coast...more

Seyfarth Shaw LLP

Year-End Estate Planning for 2023

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A strong stock market and “soft landing” have generated significant wealth this year. The gift tax, estate tax and generation-skipping transfer tax are all imposed on the fair market value of assets at the time of transfer....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 - 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

Skadden, Arps, Slate, Meagher & Flom LLP

The 2024 Green Book and Tax Implications: A Primer

On March 9, 2023, the Treasury Department released the General Explanations of the Administration’s Fiscal Year 2024 Revenue Proposals (sometimes called the Green Book) to accompany President Joe Biden’s proposed budget for...more

Rivkin Radler LLP

Sale to IDGT, Death of Grantor, Basis Step-Up: Treasury’s Priority Guidance & the Dems’ Loss of the House

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Some folks eagerly await the release of a new album. Others camp outside of big box retailers to get the jump on holiday gifts. There are those who line up at box offices to purchase tickets for a concert that is months away....more

Harris Beach Murtha PLLC

IRS Looks to Limit Estate Tax Break For Large Gifts in Tweak to Anti-Clawback Regulations

The Treasury Department issued proposed regulations on Tuesday, April 26, 2022 in follow up to the anti-clawback regulations published on November 26, 2019. The 2019 anti-clawback regulations were in response to the Tax Cuts...more

Mintz - ML Strategies

House Democrats Weigh Major Tax Changes for Businesses, Funds, and Individuals

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In May 2021, President Biden’s administration released a $6 trillion budget proposal for the coming fiscal year (Budget), including $3.6 trillion of tax increases over 10 years and generous tax credits to incentivize clean...more

Rivkin Radler LLP

Grantor Trusts On The Precipice?

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Where Are We? Have you seen the Triumvirate of late? No, not Julius, Pompey, and Crassus. I’m referring to more contemporary political figures, whose names and exploits are not likely to appear in volumes that will be...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Estate and Gift Planning with Low Interest Rates - Making the Best of a Bad Situation

Because of the current pandemic, the August 2020 applicable federal rates and section 7520 rate are at historical lows, creating opportunities for interest sensitive estate and gift tax planning. Loans to family members or...more

Cozen O'Connor

Tax Update: The Impact of Newly Published Regulations on the Estate and Gift Tax Laws

Cozen O'Connor on

In November 2019, almost two years after the enactment of the comprehensive overhaul of the Internal Revenue Code, the Department of the Treasury published regulations to clarify the impact of the new law on the estate and...more

Stinson LLP

IRS Eliminates Worry About "Clawback"

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In response to Internal Revenue Code Section 2001(g)(2), enacted as part of the 2017 Tax Act, in which the Secretary of the Treasury was directed to prescribe regulations to carry out IRC Section 2001(g) with respect to the...more

Holland & Hart LLP

New IRS Addresses for Filing Estate Tax Returns

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The Instructions for Form 706 released in November 2018 included new addresses; however, we felt a reminder could be useful since the filing address changed mid-year...more

Bradley Arant Boult Cummings LLP

Proposed Tax Regulations Eliminate Possibility of Clawback of Lifetime Gifts for Estate Tax Purposes

As previously posted, the Tax Cuts and Jobs Act signed into law in December 2017 (the “2017 Act”) made significant changes to the federal wealth transfer system with respect to gift and estate tax transfers during the...more

BCLP

New IRS Addresses for Filing Estate and Gift Tax Returns

BCLP on

Beginning this year, estate and gift tax returns have new filing locations, according to the instructions for Form 706 and Form 709. As of June 30, 2019, estate tax returns (Forms 706) filed using the United States Postal...more

Proskauer Rose LLP

Personal Planning Strategies - December 2018

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Estate, Gift and GST Tax Update - What This Means for Your Current Will, Revocable Trust and Estate Plan - The estate and gift tax regimes have been permanent and unified since the passage of The American Taxpayer...more

Holland & Hart LLP

Clarification Regarding Deduction of Expenses by Trusts and Estates

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In Notice 2018-61, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) announced that they plan to issue regulations clarifying the impact of Internal Revenue Code section 67(g) on the...more

Williams Mullen

IRS to Address Questions About Code § 67(G)

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On Friday, July 13, 2018, the U.S. Department of the Treasury (the “Treasury”) and the IRS published Notice 2018-61 (the “Notice”), stating that they plan to issue regulations providing clarification of the effect of § 67(g)...more

Holland & Knight LLP

Congress Releases Revised Conference Bill on Tax Reform - A Look at How It Compares with Earlier House and Senate Bills

Holland & Knight LLP on

Congress released the "Tax Cuts and Jobs Act" on late Friday evening, Dec. 15, 2017. This version of the bill is the result of a conference committee process to marry the different bills previously passed by the U.S. House of...more

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