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.
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TOPICS / ESTATES
Estate Tax
Qualified opportunity zones provide estate planning options
Investors with significant capital gains should investigate opportunities to reinvest their cash within designated QOZs to take full advantage of this tax boon.
Estate and gift exclusion clawback addressed in proposed regs.
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.
Recent developments in estate planning: Part 1
This first of a two-part article discusses legislative,
gift, and estate tax developments.
IRS simplifies procedure to request relief for late portability elections
This article discusses the relief available when an executor misses filing the election to make estate exclusion amount portable.
Reporting foreign trust and estate distributions to U.S. beneficiaries: Part 2
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.
Reporting foreign trust and estate distributions to U.S. beneficiaries: Part 1
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.
Recent developments in estate planning: Part 1
This first of a two-part article discusses gift and estate tax developments.
IRS allows certain estates an extension of time to make portability election
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.
IRS provides simplified method to request an extension of time to make a portability election
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.
Valuation of family-owned entities for estate and gift tax purposes under Sec. 2704
This article discusses the rules governing the
effects of lapses and restrictions on voting or liquidation rights of owners on the valuation of
family-held entities.
IRS notice permits recalculation of marital deductions for same-sex couples
The IRS provided the procedures same-sex married couples should use to recalculate the transfer-tax
treatment for property transferred to spouses.
IRS Permits Same-Sex Couples to Recalculate Marital Exclusion Amounts
The IRS spelled out the procedures same-sex married couples should use to recalculate the transfer-tax treatment for property transferred to spouses before the U.S. Supreme Court invalidated Section 3 of the Defense of Marriage Act.
Account Transcripts Can Substitute for Estate Tax Closing Letters
Account transcripts that contain a specific transaction code and wording can serve as the equivalent of an estate tax closing letter.
Understanding Qualified Domestic Trusts and Portability
This article discuses how transfer-tax rules for noncitizen spouses differ from the transfer-tax rules that apply to spouses who are U.S. citizens or residents.
QTIP Election Permitted Together With Portability
The IRS will treat a QTIP election as valid in certain situations, including where an executor
of an estate makes a portability election to transfer the decedent’s unused applicable exclusion amount.
Tax Planning Opportunities for Tax Attributes and the Decedent’s Final Tax Return
Careful and thoughtful advanced planning can result in substantial tax savings.
Consistent Basis Reporting Between Estates and Beneficiaries
Executors and practitioners will have to deal with questions and inconsistencies until the IRS addresses them.
Estate Valuation Discounts Would Be Prohibited Under Proposed Regulations
The IRS issued long-awaited proposed regulations designed to prevent taxpayers from lowering the estate and gift tax value of transferred assets.
Late Portability Elections After the Expiration of Rev. Proc. 2014-18
This item discusses relief available to the executor of an estate that fails to elect portability by failing to timely file an estate tax return.
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.
