Taxpayer transferred his house to his parents who, in exchange, paid off his existing mortgages on the residence (approx. $664,000). The taxpayer incurred almost $17,000 in closing costs.
Private split-dollar arrangements (“SDAs”) typically involve a trust creator (“grantor”) that advances life insurance premiums on behalf of his or her irrevocable life insurance trust (“ILIT”), subject to a repayment right for such advances (the “SDA receivable”).
Less than three years prior to his passing, decedent transferred artwork to a limited liability company (LLC) and subsequently made gifts of his interest in the LLC to his nieces. The nieces executed gift acceptance agreements in which each of them agreed to pay the gift taxes, if any, relating to the gifts of the…
Washington Court Holds Ex-Spouse Not Named as Beneficiary Entitled to Only Portion of Decedent’s Life Insurance Proceeds
Topics: Estate planning
A Washington Court of Appeals affirmed the trial court’s judgment in favor of decedent’s daughter, who was named as beneficiary of the decedent’s life insurance policy, ruling that, even though the decedent violated a temporary order and final dissolution decree by naming his daughter as the beneficiary under his policy, the decedent’s ex-spouse was entitled…
To support and incentivize charitable giving, the Internal Revenue Code (“Code”) provides an income tax deduction for contributions to qualified charities. The substantiation requirements for claiming the income tax deduction for charitable donations, however, are numerous and complex, especially for non-cash gifts.
The Fiscal Year 2018 Budget Support Act of 2017 (“Act”) will impact a range of tax provisions, including to increase the D.C. estate tax exemption to conform with the federal estate tax exemption.
In related PLRs, the IRS reviewed whether an affirmative allocation of GST exemption to a gift transfer to an irrevocable trust was effective despite husband’s and wife’s respective failure to attach a Notice of Allocation to their timely filed gift tax returns and their election out of the automatic allocation rules.
In PLR 201731006, the IRS granted an extension of time for a trustee to sever a Marital Trust into GST exempt and non-exempt trusts for the purpose of making a reverse QTIP election with respect to the GST-Exempt Marital Trust. The Service also ruled that the automatic allocation rules pertaining to GST exemption apply to…
In a series of PLRs, the IRS ruled on the implications of converting a non-grantor charitable lead annuity trust (“CLAT”) into a grantor CLAT by amending the trust agreement to include the power of substitution.
Trust decanting allows a trustee to transfer assets from an existing irrevocable trust to a different irrevocable trust and may be used to address a wide array of issues, including correcting drafting errors, changing distributions standards or beneficiary powers of appointment, amending administrative provisions, and updating fiduciaries and their powers.