Estate Tax Inclusion

On April 27, 2022, the IRS released proposed regulations that follow up on the initial “Anti-Clawback” regulations released in 2019. The proposed regulations provide guidance on how various estate planning strategies may be treated in…

In this webinar, the panelists will analyze the Powell case and provide their insight on how it may impact estate planners advising existing family entities.

This presentation will go through the “ok’s” and “not ok’s” of trusts created for other family members including a spouse and minor children.

This article discusses some potential estate tax problems that may arise on account of rights or powers conferred under local law. In particular, it will discuss section 411(a) of the Uniform Trust Code (UTC), which has been adopted in many…

In Strangi, the Tax Court eliminated all estate tax discounts for a family partnership. The authors note, it held, as it had in several prior. cases, that section 2036(a)(1) required this result. The court then went on to reach the…

The Strangi case has undergone a significant trip so far through the court system (and additional travel for it may arise). Estate of Strangi v. Commisioner, 115 TC 478 (2000)(“Strangi I”), aff’d in part and remanded in part, 293 F.3d 279…

In Estate of Strangi v. Commissioner, T.C. Memo 2003-145, the United States Tax Court held that the full fair market value, as of the date of the decedent's death, of the underlying assets of a family limited partnership in which the…

It has long been accepted as nearly axiomatic, from a wealth tax planning perspective, that lifetime gifts and other transfers are more efficient than deathtime transfers. Two common reasons account for this.

Although qualified personal residence trusts or QPRTs are the most common way for an older family member to transfer one or two homes to younger family members, a Split Purchase Trust may be more where a new home is being acquired—the Split…

Unless falling under an exception, exclusion or special rule, a generation-skipping transfer tax is imposed by IRC §2601 whenever property is transferred through or around one younger generation (such as the generation of the transferor's…