Regulations are anticipated to clarify that the costs of trust or estate administration that are deductible under Sec. 67(e)(1) are not miscellaneous itemized deductions and, therefore, their deductibility has not
been suspended by Sec. 67(g).
Taxation of Estates & Trusts
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.
Claiming the QBI deduction for trusts
The enactment of Sec. 199A provides one more reason to advise clients to create separate trusts for individual beneficiaries instead of a single trust.
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 2
This article is the second of two parts of an annual update on developments in trust, estate, and gift taxation. It covers generation-skipping transfer tax and trust tax developments, as well as inflation adjustments for 2018.
Recent developments in estate planning: Part 1
This first of a two-part article discusses legislative,
gift, and estate tax developments.
Income taxation of trusts in California
The California Superior Court determined that all income, including California-source income, is subject to the apportionment formula.
IRS gets decedent’s share of proceeds from asset sale
The IRS was entitled to an estate’s share of the proceeds from the sale of limited partnerships’ assets after it intervened in a suit between the estate and the partnerships.
Revenue procedure contains tax rate tables and inflation adjustments under new tax law
The IRS announced new lower tax brackets for 2018 and a number of other new items affected by the Tax Cuts and Jobs Act.
Income taxation of trusts and estates after tax reform
This item offers an overview of the main amendments to the income taxation of trusts and estates included in the TCJA.
Reporting foreign trust and estate distributions to U.S. beneficiaries: Part 3
This last article in a three-part series contains an analysis of the tax reporting of the net income distribution to a U.S. beneficiary of a foreign nongrantor trust.
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.
Foreign trust DNI, UNI, and the throwback rules: Important tax planning strategies
Foreign nongrantor trusts with U.S. beneficiaries have always been highly regulated under the throwback rules .
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 2
This second of a two-part article discusses GST tax and trust tax developments, as well as tax reform proposals and inflation adjustments for 2017.
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.
Disclaimers as a fix for old trusts
The use of a disclaimer by a trust beneficiary may be helpful to adjust the results of a previously established irrevocable trust.
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.
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.