On November 26, 2019, the Treasury Department and the IRS issued final regulations under Section 2010 which provided taxpayers with some much needed assurance that they would not be punished for utilizing their gift and estate tax exclusion (“Exclusion”) during their lifetime if Exclusion amounts were lower when they died (“Anti-Clawback Regulations”).[1] See Josh Sage’s…
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In a previous article, we discussed the basics of Spousal Lifetime Access Trusts (“SLATs”).[1] Generally, SLATs are irrevocable trusts established by one spouse during such spouse’s lifetime with the other spouse being a beneficiary of the trust. Often both spouses will establish a SLAT, but they must be carefully structured and administered to prevent application…
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***This article is a follow-up to a prior article from 2019 which can be found here. Life insurance is a great tool that can serve a variety of purposes. Most often, it is thought of as an income replacement/hedge against premature death to provide for one’s family, and it is certainly a great tool to…
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Spousal Lifetime Access Trusts (“SLATs”) are one of the many estate planning tools available to taxpayers, and have seen a surge in popularity recently, such that they are one of the most used options for utilizing taxpayers’ federal lifetime gift and estate tax exclusion (“Exclusion”) during life. Each taxpayer’s Exclusion amount, or the amount which…
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The IRS Office of Chief Counsel recently issued CCA 202152018 (“CCA”), in which the IRS is attacking yet another business valuation.[1] The IRS takes the position in the CCA that because the valuation used failed to account for a potential acquisition, the grantor retained annuity trust (“GRAT”) failed to properly qualify as a GRAT even…
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Since we’re the cool, diamond-handed, trendy-loving, FUD(fear, uncertainty, and doubt)-crushing, FOMO(fear of missing out)-haters and at the same time professionals, now seems just as good of time as ever to discuss what we are doing at our firm to familiarize ourselves and become more competent in the ever-growing and evolving world of magic internet money,…
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Under current law, the unified credit against estate and gift tax sits at $10,000,000, subject to indexing for inflation (the “Exemption”).[1] As a result of the Tax Cut and Jobs Act, this number increased from $5,000,000 effective January 1, 2018 and through December 31, 2025, with the number set to drop back down to $5,000,000on…
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Earlier this year I discussed President Joe Biden’s proposed tax policies, which was prepared in anticipation of President Biden’s impending announcement regarding the Build Back Better Act.[1] As we approach the end of the Biden administration’s first year, tax professionals are on the edge of their seat. A plethora of different legislative changes directed at…
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In a recent case out of the United States District Court for the District of Connecticut, the Court denied the IRS’ motion for summary judgment and refused to aggregate the gift of partial interests in real estate together for purposes of valuing the gifts and thus determining appropriate discounts.[1] The IRS alleged that no discount…
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In May of this year the U.S. Tax Court issued a memorandum of opinion on the value of several assets included in the Estate of Michael Jackson (“Estate”) for federal estate tax purposes.[1] This opinion comes more than a decade after Jackson’s death in June of 2009 and provides some resolution (albeit subject to appeal)…
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