News & Analysis as of

Estate Tax Internal Revenue Service Internal Revenue Code (IRC)

Estate taxes, also known as inheritance or death taxes, are taxes on an individual's right to transfer property at death.
ArentFox Schiff

The Sunset of the Doubled Estate, Gift, and GST Tax Exclusion Amounts After December 31, 2025

ArentFox Schiff on

The TCJA doubled the lifetime exclusion and GST tax exemption. This exclusion amount, adjusted for inflation, is now $13.61 million and is expected to be approximately $13.99 million in 2025. However, in 2026, the amount will...more

Pillsbury Winthrop Shaw Pittman LLP

IRS Issues Proposed Updates to Qualified Domestic Trust Regulations

The proposed regulations update outdated references and information under the current regulations, including references to temporary regulations, IRS officials, offices and addresses. The proposed regulations conform with...more

Husch Blackwell LLP

Unanimous Supreme Court Determines Company-Owned Life Insurance Increases Fair Market Value

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On June 6, 2024, the Supreme Court held 9-to-0 in Connelly v. United States that company-owned life insurance increases the company’s fair market value for estate tax purposes, and the company’s obligation to redeem a...more

Rivkin Radler LLP

BEWARE: Redemption Agreement Funded with Corporate-Owned Life Insurance

Rivkin Radler LLP on

On June 6, 2024, in the case of Connelly v. United States, the United States Supreme Court determined that corporate-owned life insurance proceeds used to redeem a decedent’s shares in the corporation must be included when...more

ArentFox Schiff

US Supreme Court Affirms the Eighth Circuit’s Decision in Favor of the Government Concerning the Estate Tax Treatment of Life...

ArentFox Schiff on

In Connelly v. US, 602 US ___ (6/6/2024), the US Supreme Court affirmed a decision of the US Court of Appeals for the Eighth Circuit in favor of the government concerning the estate tax treatment of life insurance proceeds...more

Husch Blackwell LLP

Understanding the 2026 Changes to the Estate, Gift, and Generation-Skipping Tax Exemptions

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The Tax Cuts and Jobs Act of 2017 provided major changes to the Internal Revenue Code, specifically doubling the federal estate, gift, and generation-skipping transfer (GST) tax exemption (collectively, the exemption) from...more

DarrowEverett LLP

Maximizing QSBS Benefits with Estate Planning: The Art of Stacking

DarrowEverett LLP on

The number of taxpayers seeking the benefits of Qualified Small Business Stock (“QSBS”) has picked up steam in recent years, particularly since the Tax Cuts and Jobs Act (“TCJA”) lowered the federal corporate tax rates to...more

Kilpatrick

Death, Taxes, and the Sale of Business Interests

Kilpatrick on

Introduction: What is Estate Tax and Who Has to Pay? Over 200 years have passed since Benjamin Franklin famously wrote, “in this world, nothing can be said to be certain, except for death and taxes.” This sentiment still...more

Gray Reed

Tax Court Decision on Family Business Affecting Income Tax, Estate Tax

Gray Reed on

In a recent Tax Court decision, the court reviewed the activities of the Huffman family as it pertained to corporate dealings involving the family aviation business (Infinity Aerospace Inc. which the court refers to by its...more

Freeman Law

IRS Form 709 | Gift and Generation | Skipping Transfers: Recent Updates and Common Mistakes

Freeman Law on

Fewer taxpayers are subject to gift taxes thanks to a $12,920,000.00 lifetime gift tax exemption for 2023. Because many taxpayers do not fall under the exemption amount, they do not necessarily have to file a gift tax return....more

Blank Rome LLP

Avoiding Zero Basis for Inherited Assets

Blank Rome LLP on

Practitioners involved with the administration of trusts and estates of a decedent may be confronted with the issue of dealing with one or more assets of a decedent discovered after the administration is believed to have been...more

Gray Reed

The Fine Print: IRS Examination of Artwork

Gray Reed on

Many taxpayers have art collections. However, the art collections of some high-net-worth individuals, family offices, and business taxpayers may draw the unwanted eye of the IRS. With the increased focus on auditing...more

Hinckley Allen

Understanding 2024 Estate, Gift, and Generation-Skipping Transfer Tax Exemptions

Hinckley Allen on

Each year, certain estate, gift, and generation-skipping transfer (“GST”) tax figures are subject to inflation adjustments that go in effect on January 1. Below are the current adjustments for 2024....more

Pullman & Comley, LLC

Ringing in 2024 with Updates on Estate and Gift Taxes

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The New Year brings with it new estate and gift tax exemption and exclusion amounts.   In 2017, a new tax law doubled the federal estate and gift tax exemption. And that exemption amount has increased each year between 2018...more

McDermott Will & Emery

West Coast Forum 2023 | Key Takeaways

McDermott Will & Emery on

McDermott’s Private Client Practice led interactive discussions on a broad range of topics pertinent to ultra-high-net-worth families, their family office representatives and other advisors at our Private Client West Coast...more

Bilzin Sumberg

Inflation Adjustments for 2024: Key Information for International Private Client Practitioners

Bilzin Sumberg on

The IRS recently released its inflation adjustments for 2024. International private client practitioners should note the following: US Estate and Gift Tax Exclusion Amount: $13,610,000 (up from $12,920,000)...more

DarrowEverett LLP

IRS Response to Israel’s Declaration of War: Relief to Impacted Taxpayers, But Extensions Granted to Its Enforcement Arm

DarrowEverett LLP on

In IRS Notice 2023-71 (the “Notice”), the Internal Revenue Service (“IRS”) granted a postponement until October 7, 2024 for various time-sensitive filing and payment deadlines for taxpayers affected by the terrorist attacks...more

Pillsbury Winthrop Shaw Pittman LLP

Estate and Tax Planning 2023 Update: Act While You Can

Although the IRS is now on high alert for wealthy individuals, new and existing planning opportunities are available, such as tax-free gifts and other advantageous planning. Wealthy individuals and families should take...more

Lerch, Early & Brewer

IRS Levy Allowed on Classic Italian Cello to Satisfy Outstanding Estate Tax Liabilities

Lerch, Early & Brewer on

United States v. Firestone - In United States v. Firestone, the United States (Government or U.S.) sought to enforce a judgment against Defendant Omar Firestone (Omar) for outstanding tax liabilities related to the Estate of...more

Goulston & Storrs PC

Massachusetts Doubles Estate Tax Threshold as Part of $1 Billion Tax Reform Act

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On October 4, 2023, Massachusetts enacted a new law called “An Act to improve the Commonwealth’s competitiveness, affordability, and equity” (the “Act”). The Act makes several tax law changes relevant to Massachusetts...more

Blank Rome LLP

IRS Disallows Step-Up in Tax Cost Basis for Assets Held by an Irrevocable Grantor Trust

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Under current law, assets acquired from a decedent receive an adjustment in cost basis to fair market value, thereby potentially eliminating significant unrealized gain. Although Congress has and likely will use this tax...more

Rivkin Radler LLP

Transferee Liability for Estate Tax: The Downside of Being a Beneficiary

Rivkin Radler LLP on

Death of a Parent- In the context of a family-owned business, it is often the case that the matriarch or patriarch of the family is also the chief executive of the business. They may have founded the business, or they may...more

ArentFox Schiff

Section 501(c)(4) and the Social Welfare Organization

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On September 14, 2022, The New York Times published an article detailing the Chouinard family’s transfer of the majority of their ownership interests in Patagonia to a 501(c)(4) nonprofit organization....more

Proskauer Rose LLP

Wealth Management Update - April 2023

Proskauer Rose LLP on

The April Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.0%. The April applicable federal rate (“AFR”) for use with a sale to a defective grantor trust or intra-family loan...more

UB Greensfelder LLP

[Webinar] Gifting Beyond the Holidays - December 12th, 12:00 pm - 1:00 pm EST

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Gifting is a critical element of estate planning for high net worth individuals. Ulmer Trust and Estate attorneys Kim Stein, Abbie Pappas, and Erica Carducci will discuss gifting methods, including gifts utilizing the annual...more

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