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.
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TOPICS / ESTATES
Estate Tax
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.
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.
The final countdown: Benefiting from the higher BEA before it potentially expires
With the basic exemption amount for estate, gift, and generation-skipping transfer taxes set to be cut in half after the end of 2025, tax advisers can lead clients in planning and taking action now.
Proposed regulations update QDOT regulations
Changes to the qualified domestic trust regulations under Sec. 2056A would include defining when the value of assets passing to the trust is “finally determined.”
Life insurance proceeds not includible in estate
Proceeds from life insurance on decedent not includible in his estate.
Connelly clarifies estate treatment of stock redemption
The Supreme Court held that a corporation’s stock redemption obligation was not a liability that reduced the corporation’s value for estate tax purposes.
Final regs. issued on consistent-basis and basis-reporting rules
The IRS issued guidance for recipients of property from decedents on the basis-consistency requirement and for executors and others on basis-reporting requirements.
Supreme Court: Obligation to redeem stock was not a liability
The value on an estate return of shares in a closely held company were erroneously offset by the redemption obligation, the Court held.
Supreme Court: Insurance proceeds increase corporation’s estate tax value
In a unanimous decision, the Supreme Court holds that life insurance proceeds a corporation receives to fund a share redemption agreement increases the corporation’s estate tax value.
The Sec. 645 election to treat a trust as part of the estate
A Sec. 645 election can streamline tax reporting and offer other tax advantages when a client with a living revocable trust dies. Read about the requirements for making a Sec. 645 election, the tax benefits of making the election, and how and when to make the election.
Wealth transfer strategies amid shifting interest rates
Advisers must consider changes in interest rates when recommending the most advantageous estate and gift planning vehicles and strategies.
Supreme Court to decide estate tax impact of life insurance in closely held businesses
This term, the Supreme Court will answer the questions regarding the estate tax treatment of life insurance proceeds received by a closely held business and its shareholder redemption obligations. It heard oral arguments last week.
Top 8 estate planning factors for real estate
Layered on the strategies common to many estates are special considerations for clients owning substantial real property interests.
Qualified small business stock: Gray areas in estate planning
Gain exclusion under Sec. 1202 can be an attractive wealth-transfer strategy, but it is marked by a dearth of IRS guidance and consequent ambiguities and uncertainties in practice.
Recent developments in estate planning: Part 2
This second installment of an annual update on trust, estate, and gift taxation covers gift and generation-skipping transfer taxation plus inflation adjustments and legislative proposals in the president’s proposed budget for fiscal 2024.
Rev. Rul. 2023-2’s impact on estate plans
Depending upon the size of their estate, as well as other factors, an irrevocable trust may still be the best answer.
Recent developments in estate planning: Part 1
This first of two articles discusses tax issues of formation and administration of trusts and estate
taxation.
IRS signals it will challenge IDGT basis step-up at death
The IRS recently published Rev. Rul. 2023-2, which publicly announced that the Service will be challenging a basis step-up for assets in intentionally defective grantor trusts.
US estate tax: Not just for US citizens
The application of U.S. estate tax laws to a non–U.S. citizen depends on domicile, situs of assets, and application of a treaty.
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.
