Estate planners eager to help their clients make the most of the temporarily doubled estate and gift tax exemption have a daunting array of planning techniques to pick from with no one-size-fits-all solutions. “We’ve got a whole bunch of options...
Taxation Articles
6 Months In, Stock Option Deferral Rule Not Catching On
A provision in the new tax law allowing for tax deferral on some stock options may have been appealing in theory, but six months later, it’s a non-starter for most companies. IRS guidance could make the provision more attractive, but some of the...
Experts at ALI CLE Program Forecast the Future of Code Sec. 162(m) Planning
The Tax Cuts and Jobs Act (TCJA) added major limitations on the deductibility of compensation paid to top executives of companies with publicly-traded securities. The $1 million limit in Code Sec. 162(m) on the deduction of compensation paid...
Practitioners Describe Way Around ‘Black Widow’ Gift Tax Limitation
Wealthy widows and widowers on the lookout for other partners can multiply their estate and gift tax exclusions thanks to taxpayer-friendly regulations that Congress has declined to reverse so far. “Congress was worried about the ‘black widow’ who...
QTIP Trusts Could Allow Big Gifts With Small Costs
Wealthy individuals concerned that the higher estate and gift tax exemptions will disappear in 2026 can use a special trust planning technique to ensure they use up their bonus exclusion amount without giving up much. Those who are interested in...
Non-Grantor Trusts May Sneak Services Into Passthrough Deduction
The exclusion of several professional service fields from the benefits of the new pass-through deduction left many professionals dismayed, but non-grantor trusts could help bypass that obstacle. Grantor trusts have been the entity of choice for...
Alimony, Trust Tax Changes Make 2018 ‘Year of Divorce’
The Tax Cuts and Jobs Act’s delayed repeal of the deductibility of alimony payments and a provision governing trusts in cases of divorce may add some urgency to couples looking to separate. “As a tax policy matter, we encourage divorce in 2018,”...
Practitioners Fret Over Deductibility of Executor, Trustee Fees
Although the IRS has indicated that regulations addressing the deductibility of estate executor and trustee fees are coming, practitioners say the ultimate outcome is far from certain. At issue is how the temporary repeal of miscellaneous itemized...
Estate Tax Changes: Past, Present, and Future
The following publication, Estate Tax Changes: Past, Present, and Future, is part of the course materials to be discussed, in part, by Ronald Aucutt at the ALI CLE Planning Techniques for Large Estates 2018 conference on April 25-27, 2018....