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.
Estate Tax
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 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
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.
Unprecedented opportunities in gift planning
For clients who are projected to have a federally taxable estate and desire to gift assets to heirs, now may be the right time to implement planning strategies
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).
Foreign trust reporting: Beware of late-filing penalties
Late-filing penalties for foreign trust filings can be devastating to clients and a significant challenge to CPAs trying to explain or eliminate them.
IRS rules eliminate estate and gift tax clawback
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.
Business entity selection after the TCJA: Post-death considerations
This discussion considers some of the key differences that affect post-mortem planning when looking at entity selection.
Split-dollar agreements and estate inclusions: Estate of Cahill
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.
Final regs. eliminate estate and gift tax clawback
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.
Recent developments in estate planning: Part 2
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.
Estate planning for digital assets
A well-drafted estate plan should address the management and distribution of digital assets to mitigate additional administrative burdens on fiduciaries.
Estate planning for the other 99%
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.
IRS proposes rules on estate and gift tax clawback
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.
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.
