News & Analysis as of

Transfer Taxes Internal Revenue Service

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The proposed regulations update outdated references and information under the current regulations, including references to temporary regulations, IRS officials, offices and addresses.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

Rivkin Radler LLP

Estate, Gift, GST & Related Income Tax Proposals – What is the White House Doing?

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Earlier this week the White House released its Fiscal Year 2025 Budget. Of course, the federal government has not yet adopted a budget for the Fiscal Year 2024 even as we approach that year’s halfway mark. But I digress. The...more

Rivkin Radler LLP

Taxes and the 2024 Election: ‘Tis the Season to Plan and Act

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This is The End- I have dreaded the year end for as long as I can remember. As a teenager and then as a young adult I associated the final quarter of the year, and especially the period beginning on Thanksgiving and...more

Rivkin Radler LLP

Disclaiming to Save Taxes

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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

Rivkin Radler LLP

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

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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

Fenwick & West LLP

IRS Issues Revenue Ruling 2023-14 on Staking

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On July 31, 2023, the IRS issued Revenue Ruling 2023-14, which sets forth the IRS’s position as to when certain staking “rewards” are taxable income. The Ruling analyzes a fact pattern where a cash method taxpayer “stakes...more

Katten Muchin Rosenman LLP

Keep It in the Family: Three Tips for Preserving Family Business Interests

As a family business owner, are you missing out on valuable estate and wealth transfer planning opportunities or jeopardizing your current plan altogether? Katten recently hosted a program that addressed common concerns,...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

Husch Blackwell LLP

Estate Planning Solutions for Year-End 2022 and Beyond

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By most accounts, 2022 has been a tumultuous year from a planning perspective: the uncertainty of the midterm elections, stock market volatility, rising interest rates and the highest level of inflation in recent history have...more

Moritt Hock & Hamroff LLP

IRS Grants Major Extension To Make “Portability” Election For Estates Not Required To File Estate Tax Returns From 2017 To Present

IRS Alert: The Internal Revenue Service (“IRS”) recently issued Revenue Procedure 2022-32 which provided surviving spouses extended relief to make “portability” elections without the need for the issuance of a private letter...more

Williams Mullen

[Webinar] December 2022 Tax Forum - December 1st, 9:00 am - 10:00 am ET

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Join Williams Mullen for our Winter Tax Forum on Thursday, December 1, 2022, where Farhad Aghdami will provide an update on recent wealth transfer tax developments and Kevin Bender will provide an update on a new IRS revenue...more

Roetzel & Andress

Rising Inflation Affects Ceilings on Retirement Contributions, Transfer Tax Credits and Income Tax Brackets for 2023

Roetzel & Andress on

The IRS on Friday announced a historic increase in contribution limits to 401(k) and other qualified retirement plans. In 2023, you may contribute up to $22,500 to your 401(k), 403(b) and most 457 plans, which represents more...more

Rivkin Radler LLP

Moving to the U.S.? Have You Planned for the Estate and Gift Taxes?

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It is a fact that the phenomenon of human migration has been a major force in the history of the world. Indeed, among the themes that have remained constant during my years of practice, there are two that may be...more

Jones & Keller, P.C.

Taking the Sting Out of Death Taxes with Dylan Metzner, Jones & Keller

Jones & Keller, P.C. on

High-net worth individuals have an opportunity to take advantage of high transfer tax exemptions if they act fast. Set to expire in 2026, unless Congress acts sooner, the time is now to implement strategies that make the most...more

Rivkin Radler LLP

New York’s Pass-Through Entity Tax, F Reorgs, and the Sale of An Electing S Corp

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Timing- I had planned to post this piece during the third week of December, a day or so after the exchange between Senator Manchin and the White House sealed the fate of the Build Back Better plan, at least in its current...more

Greenberg Glusker LLP

IRS Announces 2022 Inflation Adjusted Amounts For Transfer Taxes

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The IRS recently confirmed that, for 2022, the aggregate amount that can be given away without being subject to the gift or estate tax will increase to $12.06 million per individual. Thus, as of 2022, a married couple...more

Rivkin Radler LLP

One Step Closer to “Building Back” – Where Do Federal Transfer Taxes Stand?

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Tax the Rich? The President’s plan for a tax regime that would ensure the rich pay their “fair share” of the cost of implementing his programs has come one step closer to being realized . . . maybe . . . well, sort of ....more

Rivkin Radler LLP

Gift Transfers: Not on the Congressional Agenda, But Still in the Crosshairs of the IRS

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Same old in D.C.- On Monday, November 15, the President will sign into law the approximately $1 trillion Infrastructure Investment and Jobs Act that was finally passed by Congress when the House approved the Senate’s...more

Proskauer Rose LLP

Personal Planning Strategies - October 2021

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Act Now Before the Window of Opportunity Closes - By now you have probably heard that the House Ways and Means Committee introduced legislation a few weeks ago (see Let the Estate Tax Planning Games Begin - But Where Will...more

Akerman LLP

Draft Legislation in U.S. House of Representatives Would Dramatically Alter Estate Planning Strategies

Akerman LLP on

On September 10, 2021, the U.S. House Committee on Ways and Means released a draft of proposed legislation that, if enacted into law, would reduce the estate tax exemption and significantly limit the effectiveness of certain...more

Polsinelli

Impact Of President Biden’s Tax Plan On Estate Planning

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With Democratic control of the White House and Congress, there has been much speculation on what President Biden’s tax proposal will look like, as well as the likelihood that President Biden’s tax plan will be enacted into...more

Rivkin Radler LLP

Biden’s 2022 Revenue Proposal, Profits Interests, And The Alchemy Of Compensation

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Recap- Last week, we considered several of the revenue proposals included in the Biden Administration’s 2022 Budget that are probably of interest – or should we say, “of concern”? – to the owners of closely held...more

Rivkin Radler LLP

The Biden Administration’s Revenue Proposals For Fiscal Year 2022: Tax Increases And Forced Recognition Of Capital Gains

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Extra, Extra!- Last Friday afternoon, as millions of unsuspecting Americans prepared for the long Memorial Day weekend – for many, perhaps, their first mask-less holiday celebration in almost 15 months – the Biden...more

Mitchell, Williams, Selig, Gates & Woodyard,...

ILITs and the Reciprocal Trust Doctrine

Throughout 2020, as many tax attorneys and their clients continuously worried about potential changes in federal transfer tax laws that could result with an administration change, numerous articles were published and webinars...more

Goulston & Storrs PC

The New Administration Brings Several Potential Tax Law Changes

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A new Presidential administration and Congress always bring with them the potential for change, and this is again the case.  Joe Biden and his party made a series of tax law proposals throughout the presidential campaign...more

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