Estate Tax
This second of a two-part article discusses regulations on calculating the basic exclusion amount once the higher estate tax exemption expires after 2025, as well as several court cases and IRS private letter rulings.
The full value of a GRAT is includible in the grantor’s estate under Sec. 2036(a).
Late-filing penalties for foreign trust filings can be devastating to clients and a significant challenge to CPAs trying to explain or eliminate them.
The IRS issued final regulations that reconcile the current higher exclusion for the estate and gift tax unified credit amount in effect under the TCJA with the lower unified credit scheduled to go into effect in 2026.
This discussion considers some of the key differences
that affect post-mortem planning when looking at entity selection.
As a recent Tax Court case demonstrates, when dealing with property interests in certain cases, advisers must carefully consider whether Sec. 2036(a) can cause an estate inclusion of the property interests.
The IRS issued final regulations that reconcile the current higher exclusion for the estate and gift tax unified credit amount in effect under the law known as the Tax Cuts and Jobs Act with the lower unified credit, which is scheduled to go into effect in 2026, eliminating a possible future clawback of the higher exclusion amount.
This second part of a two-part article covers court cases, proposed regulations, and other IRS guidance issued over the last year on gifts and estates.
A well-drafted estate plan should address the management and distribution of digital assets to mitigate additional administrative burdens on fiduciaries.
The implications of the TJCA's large increase in the estate and gift tax exemption are complex and affect estate planning for everyone, not just the small percentage of the population who will still file estate tax returns.
The IRS addressed issues and made conforming revisions arising from the temporary increase in basic exclusion amount for estate and gift tax enacted by legislation known as the Tax Cuts and Jobs Act.
Investors with significant capital gains should investigate opportunities to reinvest their cash within designated QOZs to take full advantage of this tax boon.
The IRS addressed issues and made conforming revisions arising from the temporary increase in basic exclusion amount for estate and gift tax enacted by legislation known as the Tax Cuts and Jobs Act.
This first of a two-part article discusses legislative,
gift, and estate tax developments.
This article discusses the relief available when an executor misses filing the election to make estate exclusion amount portable.
Part 2 of this three-part series analyzes legal and beneficial ownership concepts as applied to a trust or estate created and administered in a foreign common law jurisdiction in contrast to a civil law jurisdiction.
Part 1 (of three) explains the classification criteria of a foreign nongrantor trust or foreign estate for U.S. tax purposes and the proper information reporting after U.S. taxes are withheld.
In a taxpayer-friendly development, the IRS issued guidance permitting certain estates to make a late portability election if they did not make a timely election.
This first of a two-part article discusses gift and estate tax developments.
In a taxpayer-friendly development, the IRS issued guidance permitting certain estates to make a late portability election if they did not make a timely election.
