The Internal Revenue Service (IRS) recently issued Private Letter Ruling (PLR) 202504006, addressing several important estate and gift tax questions related to the division of a marital trust and the subsequent disclaimer of...more
Through the years, the US Tax Court has provided significant clarification on the gift tax consequences of terminating qualified terminable interest property (QTIP) trusts. Two new cases in 2024, Estate of Sally J. Anenberg...more
It’s not enough for the founder of a closely held business to have successfully established the business. The business has to grow, not only to increase profits, but also to make it more competitive and to diversify its...more
I. INTRODUCTION - This outline is a selective and evolving review of the history of the modern federal estate tax. It originated during the attempts to repeal the estate tax in President Clinton’s second term and...more
Increase in Exemption from Estate, Gift and Generation-Skipping Transfer Taxes - On December 22, 2017, the Tax Cuts and Jobs Act (the "Act") was signed into law. The Act implements a variety of significant tax reforms....more
Tax Act of 2017: Transfer Tax Provisions - The Tax Cuts and Jobs Act of 2017 (the “Tax Act of 2017”) was signed by the President on December 22, 2017. The transfer tax provisions of the Tax Act of 2017 (i.e. the estate,...more
Action Item: This year, Blank Rome’s annual estate planning newsletter will be issued in six installments. Each installment will discuss certain concepts and techniques that we hope may be of interest to our clients and...more
The October § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 2.4%. This is up from September's 2.0% rate. The applicable federal rate ("AFR") for use with a sale to a defective...more
On June 26, 2013, the United States Supreme Court issued its decisions in Windsor v. United States and Hollingsworth, et. al. v. Perry et. al., thus ending a four year "fast-track" judicial expedition of the validity of the...more
Now that Congress has implemented a relatively large per person federal gift/estate tax exemption (i.e., the per person federal gift/estate tax exemption is $5,250,000 in 2013, indexed for inflation), many think that estate...more