Taxation of Estates & Trusts
In this first installment of an annual update on trust, estate, and gift taxation, the topics include estate tax closing letters, the basic exclusion amount, estate debts and expenses, and extending the time to elect portability.
The IRS released Rev. Proc. 2022-32, which updates and expands the simplified method for estates to obtain an extension of time to make a portability election under Sec. 2010(c) (5)(A).
This item summarizes the impact of two sets of proposed regulations issued by Treasury in early 2022.
The IRS extended to five years the period under which a taxpayer can use a simplified method (in lieu of a letter ruling request) to obtain an extension of time to make a portability election.
Administrative expenses and claims against estates allowable under Sec. 2053 beyond a three-year grace period would be discounted for current deduction, under proposed rules issued by the IRS.
Generally, a trust cannot hold stock of an S corporation; however, grantor trusts, testamentary trusts, voting trusts, ESBTs, and QSSTs are permissible S corporation shareholders (Sec. 1361(c)(2)).
This article compares the relative advantages and disadvantages of a QSST versus an ESBT in estate planning.
A corporate recapitalization can freeze the value of the owner’s stock, potentially reducing the owner’s estate tax liability by removing future appreciation in the value of stock from the owner’s estate.
The value of a receivable created by split-dollar life insurance arrangements is the receivable’s value, not the cash-surrender value of the insurance purchased under the arrangements
Exceptions to the special rule allowing the temporarily higher basic exclusion amount to apply to gifts credited against estate tax.
While it may take some finesse to report the most complicated transactions on Form 709, you do
not have to be a gift tax specialist to be aware of 10 common return preparation mistakes.
This article discusses what partnerships, S corporations, and their owners need to know to manage the tax risks that arise when an individual partner or shareholder dies.
It is important to consider some of the less-obvious gifts when you are advising clients who are intent on using up their full $11.7 million basic exclusion amount before the end of the year.
Today’s low interest rates make charitable lead trusts a more powerful option for tax-efficient estate planning.
These trusts can be advantageous to wealthier clients, but their future use in estate planning is threatened by current legislative proposals.
This article discusses the history of the grantor trust rules, how they are exploited to avoid taxes, and ways the rules might be reformed to prevent them from being used for tax avoidance.
This second part of an annual update examining developments in estate, trust, and gift taxation covers recent court cases, proposed regulations, and other IRS guidance on estate tax.
This first part of this annual update focuses on trust and gift tax issues.
The penalty for failure to report a distribution from a foreign trust is not reduced when the trust beneficiary is also the trust owner.
The letters, which the IRS provides as a courtesy to executors and other authorized estate representatives, will now cost $67.
