The final regulations target arrangements that the IRS says improperly use charitable remainder annuity trusts and annuities to eliminate ordinary income and capital gain on the sale of property.
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TOPICS
Taxation of Estates & Trusts
IRS offers gift tax safe harbor for contributions to Trump accounts
The guidance sets forth conditions for contributions to qualify for the annual gift tax exclusion and for donors to avoid filing gift tax returns.
IRS proposes increase in cost of estate tax closing letter
Proposed regulations issued Monday would raise the cost of the letter to $76, from the $56 set in 2025.
Multigenerational wealth transfer with IDGTs and GST tax planning
High‑net‑worth families can preserve wealth across generations by pairing intentionally defective grantor trusts with thoughtful generation-skipping trust exemption planning.
Using a GRAT or GRUT to shift appreciation and maintain control of the corporation
Use of a grantor retained annuity trust or grantor retained unitrust can mitigate the gift tax consequences of a gratuitous transfer of stock.
Trust distributions: Timing, tax, and practical considerations
This article explains the basics of trust distributions, focusing on key concepts, relevant rules and elections, and planning choices that can help trustees manage taxes for both the trust and its beneficiaries.
A case study on ILITs: What went wrong, how to fix it, and best practices for prevention
In estate planning, taxpayers and their advisers may overlook the potential generation-skipping transfer tax implications of irrevocable life insurance trusts.
Estate planning in a post-OBBBA world
Strategies for optimal intergenerational wealth transfer may require reconsideration, given the continuation of a higher basic exclusion amount by the law known as the One Big Beautiful Bill Act.
Considerations for intergenerational split-dollar arrangements
Families with significant estate tax exposure may consider intergenerational split-dollar (IGSD) arrangements, where the senior generation loans funds to a trust to purchase life insurance on children for the benefit of grandchildren.
Trust distributions in kind and the Sec. 643(e)(3) election
This article explores the strategic use of this election, highlighting its potential to optimize tax outcomes for both trusts and beneficiaries while cautioning against its pitfalls.
Estate of McKelvey highlights potential tax pitfalls of variable prepaid forward contracts
A taxpayer’s extension of variable prepaid forward contracts resulted in a constructive sale and a termination of obligations that gave rise to taxable gain, the Tax Court held.
Recent developments in estate planning
This annual update on trust, estate, and gift taxation covers recent IRS guidance and administrative issuances, relevant legislative proposals, and selected court decisions for the period ending June 2025.
Guidance on research or experimental expenditures under H.R. 1 issued
The revenue procedure advises taxpayers how to make various elections, file amended returns, and change accounting methods as provided under Section 70302 of the new law.
Tax provisions of Senate Finance’s version of the budget bill
The 549-page text calls for making many provisions of the Tax Cuts and Jobs Act permanent. The committee says that the SALT cap amount is “the subject of continuing negotiations.”
Adequate disclosure on gift tax returns: A requirement for more than gifts
Specific requirements apply to the adequate disclosure of transactions on a gift tax return.
ING trusts: How they work and their continued viability
Properly established and maintained, an incomplete gift nongrantor trust may play a valuable role in some clients’ estate plans
IRS reduces user fee for estate tax closing letters
The receipt of an estate tax closing letter generally indicates that the estate tax return’s IRS examination is closed. Final and proposed regulations lowered the fee by $11.
Limiting the unlimited charitable deduction for trusts
Although Sec. 642(c) provides for an “unlimited” charitable income tax deduction attractive to philanthropic grantors, Sec. 681 may limit a trust’s actual deduction.
Estate tax considerations for non-US persons owning US real estate
Planning options include holding the U.S. real estate through legal entities or trust structures.
Early terminations of QTIP trusts: The cautionary case of McDougall
Qualified terminable interest property trusts can be useful, but care must be taken to avoid running afoul of their requirements, as a recent Tax Court case illustrates.
TAX PRACTICE MANAGEMENT
2025 tax software survey
AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.
