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.
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TOPICS / ESTATES
Estate Tax
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.
10 estate and income tax questions
This item discusses 10 important income tax questions to consider when creating an estate plan.
Recent developments in estate planning: Part 3
In this third installment of an annual update on trust, estate, and gift taxation, the topics include generation-skipping transfer tax, trusts, private foundations, selected inflation-adjusted amounts, and the president’s and Treasury’s proposed law changes affecting trusts, estates, and gifts.
Recent developments in estate planning: Part 2
In this second installment of an annual update on trust, estate, and gift taxation, the topics include split-dollar life insurance arrangements, indirect gifts, formula clauses in transfers of limited partnership interests, valuation discounts, and grantor retained annuity trusts.
Recent developments in estate planning: Part 1
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.
Updated simplified method for estate portability elections
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).
Estate planning update: Summary of recent proposed regulations
This item summarizes the impact of two sets of proposed regulations issued by Treasury in early 2022.
Tax Court determines value of receivable from a split-dollar life insurance arrangement
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
Freezing stock value with a corporate recapitalization
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.
Tax issues that arise when a shareholder or partner dies
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.
Recent developments in estate planning: Part 2
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.
Final regulations establish a user fee for estate tax closing letters
The letters, which the IRS provides as a courtesy to executors and other authorized estate representatives, will now cost $67.
Determining whether to file a joint return in the year of death
A surviving spouse has the option to file a joint return for the deceased spouse’s year of death, but several factors must be considered to determine if this is a good idea.
Recent developments in estate planning: Part 2
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.
Full value of GRAT includible in estate
The full value of a GRAT is includible in the grantor’s estate under Sec. 2036(a).
PRACTICE MANAGEMENT
2026 tax software survey
CPAs rate their return preparation software’s performance during this year’s tax season.
