1 Estate Tax Overview Emphasis on Generation Skipping Transfers 1
2 A Brief History The Revenue Act of 1916 (39 Stat. 756) created a tax on the transfer of wealth from an estate to its beneficiaries, and thus was levied on the estate, as opposed to an inheritance tax that is levied directly on beneficiaries. It applied to net estates, defined as the total property owned by a decedent, the gross estate, less deductions. An exemption of $50,000 was allowed for residents; however nonresidents who owned property in the United States received no ex-emption.
3 The Tax Act of 1981 The Economic Recovery Tax Act (ERTA) of 1981 (95 Stat. 172) increased the unified transfer tax credit, the credit available against both the gift and estate taxes. The increase, from $47,000 to $192,800, was to be phased in over 6 years, effectively raising the tax exemption from $175,625 to $600,000 over the same period. In 1997, the 105th Congress passed the Taxpayer Relief Act of 1997 (111 Stat. 788). Among the most significant changes to estate and gift tax laws included in this act was the incremental increase of the unified credit to $345,800 by 2006, effectively raising the estate tax filing threshold to $1 million.
4 The Tax Act of 2001 The Economic Growth and Tax Relief Reconciliation Act (EGTRRA) of 2001 (115 Stat. 38) provided for sweeping changes to the transfer tax system, the most significant of which was the eventual repeal of the estate tax for Specifically, the law provided for periodic increases in the exemption amount for decedents who die after December 31, 2001, so that the effective filing threshold will be $3.5 million by 2009, then repealed for decedents who died in 2010.
5 Current Federal Estate Tax The federal estate and generation-skipping transfer taxes were resurrected by the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (P.L ) after a hiatus of one year (2010). The American Taxpayer Relief Act of 2012 (ATRA) permanently extended the estate tax rules enacted by the 2010 Act except for the top tax rate, which increased from 35% to 40% for both the estate and gift taxes. The federal estate tax is a tax on the estate of a decedent, levied against and paid by the estate. Contrastingly, the inheritance tax is imposed on and paid by the heirs of the decedent based upon the money or property that they receive. The determination of federal estate tax liability involves a series of adjustments and modifications of a tax base known as the gross estate. Certain allowable deductions reduce the gross estate to the taxable estate. Then, the total of all lifetime taxable gifts made by the decedent is added to the taxable estate before tax rates are applied. The result is the decedent s estate tax which, after reduction for certain allowable credits, is the amount of tax paid by the estate. This discussion will divide the federal estate tax into three components: the gross estate, deductions from the gross estate, and computation of the tax, including allowable tax credits.
6 CURRENT ESTATE TAX SCHEDULE The estate rate schedule is as follows: Taxable Estate Tentative Tax not over $10,000 18% of such amount $10,000-$20,000 $1, % of excess over $10,000 $20,000-$40,000 $3, % of excess over $20,000 $40,000-$60,000 $8, % of excess over $40,000 $60,000-$80,000 $13, % of excess over $60,000 $80,000-$100,000 $18, % of excess over $80,000 $100,000-$150,000 $23, % of excess over $100,000 $150,000-$250,000 $38, % of excess over $150,000 $250,000-$500,000 $70, % of excess over $250,000 $500,000 -$750,000 $155, % of excess over $500,000 $750,000 -$1,000,000 $248, % of excess over $750,000 Over $1,000,000 $345, % of excess over $1,000,000
7 Myth 1: The estate tax is best characterized as the death tax. Reality: Everybody dies, but only the richest 0.14 percent of estates pay any estate tax. The estate tax is best characterized as a tax on very large inheritances by a small group of wealthy heirs. Today, only the estates of the wealthiest 0.14 percent of Americans. Fewer than 2 out of every 1,000 people who die owe any estate tax whatsoever because of the high exemption amount, which has more than quadrupled since 2001.
8 Myth 2: The estate tax forces estates to turn over half of their assets to the government. Reality: The few estates that pay any estate tax generally pay less than one-sixth of the value of the estate in tax. Today, percent of estates owe no estate tax at all, according to the Brookings Tax Policy Center (TPC). Among the 3,780 estates that owe any tax, the effective tax rate that is, the percentage of the estate s value that is paid in taxes is 16.6 percent, on average. That is far below the top estate tax rate of 40 percent. The effective rate is so much lower than the top rate for several reasons. First, estate taxes are due only on the portion of an estate s value that exceeds the exemption level; at the current exemption level of $5.25 million, a $6 million estate would owe estate taxes on $750,000 at most. Second, heirs can often shield a large portion of an estate s remaining value from taxation through various deductions.
9 Myth 3: Many family-owned farms and businesses must be liquidated to pay taxes. Reality: Only a handful of small, family-owned farms and businesses owe any estate tax at all, and virtually none would have to be liquidated to pay the estate tax. Brookings Tax Policy Institute estimates that only 20 small business and farm estates nationwide owed any estate tax for deaths in (TPC s analysis defined a small-business estate as one with more than half its value in a farm or business and with the farm or business assets valued at less than $5 million.) This figure represents only percent of all estates that is, about one out of every 130,000 estates of people who died during the year Furthermore, these 20 estates will owe just 4.9 percent of their value in tax, on average.
10 GENERATION SKIPPING TAX The Tax Reform Act of 1986 repealed the original generationskipping transfer (GST) tax, enacted in 1976, because of its complexity and replaced it with a simplified flat-rate tax. The purpose of the resulting GST tax is the same as its predecessor, to close a loophole in the estate and gift tax system where property could be transferred to successive generations without paying multiple estate or gift taxes. The traditional generation-skipping transfers were trusts established by a parent for the lifetime benefit of the children with the remainder passing to the grandchildren. If properly drafted, an estate or gift tax would not be imposed when the trust corpus passed from the settlor s children to the settlor s grandchildren because the estate tax is not imposed on interests that terminate at death. This discussion will divide the generationskipping transfer tax into two components: generation-skipping transfers and the computation of the tax.
11 GENERATION SKIPPING TAX The GST tax is a flat-rate tax. The rate is set at the highest estate tax rate, currently 40%. This tax rate is applied to three different transfer events: a direct skip, a taxable termination, or a taxable distribution. A direct skip is a transfer to a skip person. A skip person is a person assigned to a generation two or more generations below the transferor s. A transfer to a trust is a direct skip if all the interests in the trust are held by skip persons. A taxable termination is a termination by death, lapse of time, release of power, or otherwise of an interest in property held in trust. A taxable termination does not occur if immediately after the termination a non-skip person has an interest in the property or if after the termination, the trust makes a distribution to a skip person. A taxable distribution is a distribution from a trust, other than a taxable termination or direct skip, to a skip person.
12 Highlights of Generation Skipping Transfer Tax Three systems Estate, Gift and GSTT GSTT is an excise tax imposed on the transfer of property to a donee who is two or more generations younger than the donor On top of estate and gift tax GSTT rate is equal to the maximum estate tax rate in effect at the time the generationskipping transfer (GST) occurs times the inclusion ratio 12
13 Important Step of GST An important step in determining the GST tax is to assign all persons involved to a specific generation level, as outlined in the IRC. Persons related to the transferor or spouse are assigned along family lines. For example, the transferor, spouse, and brothers and sisters are in one generation, their children in the next, and grandchildren in the next. Lineal descendants of a grandparent of the transferor or spouse are assigned to generations on the same basis. Anyone ever married to a lineal descendant of the transferor s grandparent or the spouse s grandparent are assigned to the level of their spouse who was a lineal descendant. Non-relatives of the transferor are assigned generations measured from the birth of the transferor. Persons not more than years younger are treated as members of the same generation as the transferor. Each 25- year period thereafter is treated as a new generation. A grandchild of the transferor or spouse is moved up one generation if his parents are deceased at the time of the transfer.
14 Computing GST The first step in calculating the GST tax is to determine the taxable amount. For direct skips, the taxable amount is the value of the property received by the transferee. The GST tax on direct skips is tax-exclusive, meaning that the amount of tax paid is proportional to the pretax value of the transferred property. Contrastingly, the taxable amount for taxable terminations and distributions is tax-inclusive. The taxable amount for these property transfers is determined by including the tax value with the value of the property before applying the tax rate. The second step in calculating the GST tax is to apply the applicable rate. The applicable rate is the maximum Federal estate tax rate (40% for 2014) and the inclusion ratio of the transfer. The inclusion ratio is figured by subtracting from one ( 1 ) the following fraction: the portion of the GST exemption allocated to the transfer as the numerator and the value of the property transferred as the denominator. To compute the generation-skipping tax, the value of the transfer is multiplied by the tax rate (40%) and by the inclusion ratio. The IRC provides several exemptions and exclusions for the GST tax. Unlike the estate and gift taxes, the GST tax does not use the unified credit. Instead, a $5,340,000 GST exemption is allowed to each individual for generation-skipping transfers during life or at death.61 The exemption is doubled for married individuals who elect to treat the transfers as made one-half by each spouse. An indirect skip property transfer automatically triggers the GST exemption.
15 Parties Involved in Generation Transferor Skipping Transfers (1 of 5) If transferred during life and is subject to gift tax then the transferor is the donor If transferred at death and subject to estate tax, the transferor is the decedent A new transferor is established whenever the property is again subject to estate tax or gift tax Transferee Non-Skip Person A non-skip person is any natural person or trust that is not a skip person 15
16 Parties Involved in Generation Skipping Transfers (3 of 5) Transferee Skip Person Lineal Descendants Two or more generations younger than the transferor are skip persons Unrelated and Non-Lineal Descendants If the individuals receiving the property are not lineal descendants of the transferor, they are considered skip persons if they are more than 37½ years younger than the transferor» Your generation includes anyone 12 ½ years younger and older.» Individual age 60: his generation 47 ½ - 72 ½» Next generation 22 ½ - 47 ½» Skip generation under age 22 ½ 16
17 Parties Involved in Generation Skipping Transfers (5 of 5) Transferee Skip person Trust may be skip person if: All interests in the trust are held by skip persons or If distributions can only be made to skip persons Predeceased ancestor rule If a child of the transferor is deceased at the time of the transfer then the deceased child s descendents are moved up one generation. 17
18 Types of Taxable Transfers (1 of 3) Direct Skip Outright gift to a skip person Direct skips are taxed only once regardless of how many generations are skipped GSTT on a direct skip is imposed only on the amount received by the transferee Any GSTT associated with a direct skip that is paid by the transferor is treated as a taxable gift by the transferor The transferor is generally liable for the GSTT on a direct skip If a direct skip is made from a trust, the trustee is liable 18
19 Types of Taxable Transfers (1 of 3) Taxable termination A taxable termination is any termination of a trust interest unless at the termination of the trust, the trust property transferred is subject to federal estate or gift tax, a non-skip person receives an interest in the property transferred out of the trust, or the distribution from the trust will never be made to a skip person. Taxable amount equals the value of the trust property transferred less any expenses, indebtedness and taxes attributed to the termination Trustee is liable for the GSTT on a taxable termination 19
20 Types of Taxable Transfers (1 of 3) Taxable distribution Any distribution from a trust to a skip person that is not a taxable termination or a direct skip Taxable amount equals amount received by the recipient Transferee is liable for the GSTT on a taxable distribution 20
21 Exclusions (1 of 4) Qualified Transfers Payment of tuition to a qualified educational organization on behalf of a skip person is not subject to GSTT Payment of medical expenses to a medical care provider on behalf of a skip person is not subject to GSTT 21
22 Exclusions (3 of 4) Annual Exclusion A direct skip is a nontaxable gift for GSTT purposes to the extent the transfer is excluded from taxable gifts under the annual gift tax exclusion Split gifts Gift splitting also applies to transfers subject to GSTT Enables a spouse to treat gifts of separate property as being made 1/2 from each spouse If an individual elects to split gifts for gift tax purposes, they are automatically deemed to split gifts for GSTT purposes and vice versa. 22
23 Exclusions (4 of 4) Annual Exclusion Transfers to a trust deemed a skip person are only considered nontaxable gifts for GSTT purposes to the extent the transfer is equal to or less than the annual exclusion and if: The beneficiaries are given a Crummey power The trust assets can only be distributed for the benefit of the beneficiary during the beneficiary s lifetime; and The trust does not terminate before the beneficiary s death, and the assets must be includible in the beneficiary s gross estate. 23
24 Exemption (1 of 2) GST Exemption Exemption of $5,340,000 for 2014 The GSTT exemption is allocable to inter vivos transfers and testamentary transfers Only the transferor or the transferor s executor can allocate the GST exemption to a transfer and such allocation is irrevocable If a direct skip occurs during the transferor s lifetime then the transferor s unused GST exemption is automatically allocated to the transferred property to the extent necessary to make the inclusion ratio for such property zero 24
25 Exemption (1 of 2) GST Exemption The transferor may elect out Automatically allocated at death to the extent not actually allocated on or before the due date for the transferor s estate tax return First allocated pro rata to direct skips Remaining GST exemption allocated pro rata to trusts 25
26 Applicable Rate, Inclusion Ratio and Applicable Fraction Application Fraction= GST exemption/ Taxable Property Transferred Inclusion Ratio = 100% - Applicable Fraction Applicable Rate = Inclusion Ratio x Maximum Transfer Rate (currently 40%) 26
27 Qualified Disclaimers Effect of Qualified Disclaimers A qualified disclaimer may not be used to avoid generation-skipping transfer tax 27
28 Introduction to Dynasty Trusts (1 of 4) When properly drafted, a dynasty trust will not vest ownership of trust property in any individual beneficiary The rule against perpetuities Delaware, Alaska and S. Dakota are the states where most individuals create dynasty trusts Taxation of dynasty trusts A dynasty trust pays tax on its income to the extent that the income is not distributed to the beneficiaries 28
29 Introduction to Dynasty Trusts (2 of 4) Basic Structure and Types of Dynasty Trusts Grantor funds the trust with personal property Typically ownership of family business Transfer real estate to LLC or FLP Trust document usually designates the state whose laws will govern Usually wise to name two independent trustees Individual: successors? Typically name two or more Trust Protectors who are individuals that are not beneficiaries of the trust with the authority to remove the trustee Grantor should never serve as trustee or trust protector of a dynasty trust 29
30 Introduction to Dynasty Trusts (3 of 4) Basic Structure and Types of Dynasty Trusts The trust instrument often gives the trustee the authority to terminate the trust in whole or in part if it is appropriate to do so Trustee is typically empowered to purchase assets for the beneficiary s personal use Later generation can contribute to trust, if desired Generational sub-trust generally necessary otherwise splitting assets transferred with distant cousins A dynasty trust provides creditor protection, avoidance of transfer taxation at each generational level on the value of the business, as well as protection from the claims of a divorcing spouse 30
31 General Drafting Issues for Dynasty Trusts Power of appointment usually available Limited to prevent inclusion in estate Termination usually ends when last descendent dies May have trust committee giving them the ability to terminate Tax law changes, too small to justify administration expense Trustee broad investment powers Not require diversification if holding family business Spendthrift clause appropriate 31
Chapter 18 GENERATION-SKIPPING TRANSFER TAX WHAT IS IT? This chapter discusses the generation-skipping transfer tax and planning with generation-skipping transfers, including the use of generation-skipping
CHAPTER 13 Generation Skipping Transfers DISCUSSION QUESTIONS 1. Define skip person. A natural person two or more generations younger than the transferor is a skip person. A trust is a skip person if all
Generation Skipping Transfer Tax Producer Guide For agent use only. Not for public distribution. Generation Skipping Transfer Tax Summary The generation skipping transfer (GST) tax is a complex tax. This
LIFE INSURANCE TRUSTS Robert M. Mendell, JD, CPA* Robert M. Mendell, Attorney at Law, P.C. 908 Town & Country Blvd. Suite 120 Houston, Texas 77024 (713) 888-0700 Fax: (713) 888-0800 Email: email@example.com
Gift and estate planning: Opportunities abound Vanguard research July 2013 Executive summary. Under federal gift and estate tax rules, individuals can potentially make significant gifts that are exempt
Tax Relief, Unemployment Insurance Re- Authorization and Job Creation Act of 2010 Generation Skipping Transfer-Tax Issues Estate and Gift Tax Planning Robert A. DeVellis, Esq. Blair & Potts, PC 281 Tresser
Davis & Graves CPA LLP Jerry Davis, CPA/PFS 700 N Main Gresham, OR 97009 503-665-0173 firstname.lastname@example.org www.jjdcpa.com Bypass Trust (also called B Trust or Credit Shelter Trust) Page 1 of 9, see disclaimer
estate and gift tax planning On January 1, 2013, Congress enacted ATRA. This law created certainty and provides for planning opportunities to reduce tax cost of transferring your assets to your beneficiaries.
Advisory Estates, Trusts & Tax Planning Tax March 3, 2011 New Estate and Gift Tax Laws for 2011-2012 and Transfer Tax Provisions of the President's Proposed Budget for 2012 by Jennifer Jordan McCall, Ellen
Estate Planning After the Tax Relief Act of 2010 What to Do? By Edward L. Perkins, JD, LLM CPE CREDIT - 1.0 Hour of Interactive Self-Study FIELD OF STUDY - Taxation PROGRAM LEVEL - Intermediate PREREQUISITE
Estate, Gift and Generation Tax Provisions On December 17, 2010, President Obama signed into law the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (the 2010 Tax Relief
p+pjan/feb04-web 2/2/04 2:01 PM Page 37 Income, Gift, and Estate Tax Aspects of Crummey Powers After the 2001 Tax Act, Part 1 By Sebastian V. Grassi Jr. T he need for Crummey withdrawal right trusts, such
WEALTH TRANSFER TAXES How do the estate, gift, and generation-skipping transfer taxes work?... 1 Who pays the estate tax?... 2 How many people pay the estate tax?... 2 How could we reform the estate tax?...
RETIREMENT PLANNING FOR THE SMALL BUSINESS PI-1157595 v1 0950000-0102 II. INCOME AND TRANSFER TAX CONSIDERATIONS A. During Participant s Lifetime 1. Prior to Distribution Income tax on earnings on plan
Maximizing Wealth Transfer using Innovative Trust Designs For For Producer or or Broker/Dealer Use Use Only. Only. Not Not for for Public Distribution. Why Life Insurance? Provides for: Personal family
Estate Planning Basics An Overview of the Estate Planning Process What Is an Estate Plan? An estate plan is a map This map reflects the way you want your personal and financial affairs to be handled in
Advanced Generation-Skipping Transfer Tax Issues (With Forms) (Part 1) Julie K. Kwon Julie K. Kwon is a partner in the Chicago office of McDermott, Will & Emery. Ms. Kwon chairs the Estate and Gift Tax
By Sharon L. Klein Paying for the (Grand) Kids College Know all the options and combinations thereof Rising tuition for college education is a daunting reality for many parents and grandparents. Even the
Estate, Gift, And GST Taxes: What Actually Happened Kenneth A. Goldstein The increased gift tax exemption and other provisions contained in the 2011 Act provide tremendous opportunities to save federal
ADVANCED PLANNING CONCEPTS IN LIGHT OF THE AMERICAN TAXPAYER RELIEF ACT (October 11, 2013) By: Phoebe Moffatt, Attorney CERTIFIED AS A SPECIALIST IN ESTATE AND TRUST LAW STATE BAR OF ARIZONA BOARD OF LEGAL
June 2015 Your U.S. vacation property could be quite taxing by Jamie Golombek It seems everywhere we look, Canadians are snapping up U.S. vacation properties. Though your vacation property may be located
bpq^qbi=dfcq=^ka=dbkbo^qflkjphfmmfkd== molsfpflkp=lc=qeb=q^u=obifbci== rkbjmilvjbkq=fkpro^k`b=^rqelofw^qflki= ^ka=gl_=`ob^qflk=^`q=lc=omnm== E qeb=q^u=obifbc=^`qòf= John H. Turner, III Phone 804.420.6480
Review Questions & Answers Estate Planning 2003 2015, College for Financial Planning, all rights reserved. This publication may not be duplicated in any way without the express written consent of the publisher.
THE CENTER FOR WEALTH PLANNING Wealth Transfer Planning Considerations for 2011 and 2012 March 2011 The Center for Wealth Planning is part of Credit Suisse s Private Banking USA and does not provide tax
THE FUTURE OF ESTATE PLANNING - 2012 AND BEYOND By Edward L. Perkins, JD, LLM (Tax), CPA I. The New Estate Planning Reality A. The Return of the Federal Estate Tax, et al. 1. The Estate Tax Returns After
BUILDING FLEXIBILITY INTO THE TYPICAL IRREVOCABLE LIFE INSURANCE TRUST Presented to the Kentucky Society of Certified Public Accountants, 48 th Annual Kentucky Institute on Federal Taxation, November 18,
GIFTS: THE KEY TO ESTATE TAX SAVINGS THE LAW FIRM OF ELLEN M. WINKLER 58 Atlantic Avenue Marblehead, MA 01945 Tel. 781-631-6404 Fax 781-631-7338 www.emwinklerlaw.com Estate taxes can take a significant
E s t a t e P l a n n i n g I N N O R T H C A R O L I N A Federal and State Gift and Estate Taxes Learn about federal gift and estate taxes what they are, how they are calculated, and how they may be avoided
KRISTI MATHISEN, JD AND CPA The first day of 2010 brought repeal of both the estate and generation-skipping transfer (GST) taxes. It was an occurrence that some celebrated, some bemoaned, and most expected
Irrevocable Life Insurance Trust (ILIT) Overview An irrevocable life insurance trust (ILIT) can be a useful vehicle to hold life insurance policies outside the grantor s taxable estate. When an insured
An Estate Planning Glossary The estate planning process is a complex one. During the course of your research into the firm to choose to handle your needs in administering your assets you will hear numerous
Element Insurance Partners 13520 California Street Suite 290 Omaha, NE 68154 402-614-2661 email@example.com www.elementinsurancepartners.com Grantor Retained Annuity Trust (GRAT) Page
Advisory Will and estate planning considerations for Canadians with U.S. connections Canadian citizens and residents may be exposed to U.S. estate, gift, and generation-skipping transfer tax (together,
ESTATE TAX UPDATE Fort Worth CPA Tax Institute August 7, 2015 Gary V. Post Emily K. Seawright FT WORTH DALLAS Certified Public Accountant Board Certified by the Texas Board of Legal Specialization in *Estate
What the Wealthiest Families Know: 2013 & Beyond Determine How Estate Planning Strategies and Life Insurance May Help You Turn Your Goals into a Wealth Legacy Whether you acquired it or inherited it, wealth
HISTORY, PRESENT LAW, AND ANALYSIS OF THE FEDERAL WEALTH TRANSFER TAX SYSTEM Scheduled for a Public Hearing Before the SUBCOMMITTEE ON SELECT REVENUE MEASURES OF THE HOUSE COMMITTEE ON WAYS AND MEANS on
The Wealth Plan For Mr. & Mrs. Sample Client John G. Griffin, CLU Chartered Financial Consultant April 2015 - Initial April 8, 2015 Mr. and Mrs. Sample Client Big Time Productions, Inc. 123 Smart Money
TREASURY DEPARTMENT TECHNICAL EXPLANATION OF THE PROTOCOL BETWEEN THE UNITED STATES OF AMERICA AND THE FEDERAL REPUBLIC OF GERMANY SIGNED AT WASHINGTON ON DECEMBER 14, 1998 AMENDING THE CONVENTION BETWEEN
State Bar of Texas Charitable Lead Trusts Jeffrey N. Myers Bourland, Wall & Wenzel, A Professional Corporation Attorneys and Counselors 301 Commerce Street, Suite 1500 Fort Worth, Texas 76102 (817) 877-1088
Davis & Graves CPA LLP Jerry Davis, CPA/PFS 700 N Main Gresham, OR 97009 503-665-0173 firstname.lastname@example.org www.jjdcpa.com Irrevocable Life Insurance Trust Page 1 of 9, see disclaimer on final page Irrevocable
Preserve and protect your legacy UBS Trust Company, N.A. Contents Common trust and estate planning documents.... 2 Will... 2 Living or revocable trust.... 2 Living will and health care proxy... 2 Financial
Estate and Gift Tax Planning: 2013 Update Moira S. Laidlaw, Esq. Two Depot Plaza, Suite 203 Bedford Hills, New York 10507 email@example.com Disclaimer This is an overview not a complete statement
Gift and Estate Tax Planning Insights The Perils and Prospects of Portability Jeffrey M. Cheyne, Esq. With the passage of federal tax relief laws in recent years, the porting of unused federal estate tax
GENERATION SKIPPING TRANSFER TAX (GSTT) PLANNING First Run Broadcast: September 22, 2011 Live Replay: December 22, 2011 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes) The Generation
HERMENZE & MARCANTONIO LLC ADVANCED ESTATE PLANNING TECHNIQUES - 2015 I. Overview of federal, Connecticut, and New York estate and gift taxes. A. Federal 1. 40% tax rate. 2. Unlimited estate and gift tax
Estate Planning for Non-Citizens in the United States SINGLE LIFE SPOUSAL ACCESS TRUSTS: A LIFE INSURANCE ALTERNATIVE As large numbers of people from other countries settle in the United States (U.S.),
The New Era of Wealth Transfer Planning #1 American Taxpayer Relief Act Boosts Life Insurance For agent use only. Not for public distribution. In January 2013 Congress stepped back from the fiscal cliff
STEVEN L. CANTOR HAL J. WEBB STEVEN L. CANTOR, P.A. BRICKELL BAY OFFICE TOWER SUITE 2908 1001 BRICKELL BAY DRIVE MIAMI, FLORIDA 33131 TELEPHONE(305)374-3886 FACSMILE(305)371-4564 NAPLES OFFICE SUITE 200
Immigrating to the USA: effective wealth planning Charles P LeBeau, Attorney, San Diego, California, USA Although considerations will vary widely depending on the circumstances of the specific non-resident
Planning your estate A general guide to estate planning Policies issued by: American General Life Insurance Company The United States Life Insurance Company in the City of New York What is estate planning?
SALES STRATEGY Guiding you through life. ESTATE PLANNING Spousal Access Trusts Access To Cash Value Potential Through Flexible Trust Planning The Concerns Many clients who are concerned about maximizing
Estate Tax Relief, Income Tax Headache: Estate Planning and the American Taxpayer Relief Act Thanks to the American Taxpayer Relief Act, a married couple with a properly structured estate can pass more
IN THIS ISSUE: Case Study Facts Consequences of No Planning Planning Objectives Phase 1: Reorganize & Recapitalize Phase 2: Create Dynasty Trusts Phase 3: Tom's Trust Installment Note Why Reorganize to
Checkpoint Contents Federal Library Federal Editorial Materials WG&L Journals Journal of Taxation (WG&L) Journal of Taxation 2011 Volume 114, Number 02, February 2011 Articles Estate Planning After the
On December 7, 200, President Barack Obama signed into law H.R. 4853, the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 200 (the 200 Tax Relief Act). This massive bill affects
irect Di COOPERMAN LESTER MILLER CARUS LLP ATTORNEYS-AT-LAW 1129 NORTHERN BOULEVARD MANHASSET, NY 11030 (516) 365-1400 FAX: (516) 365-1404 www.clmclaw.com CLIENT MEMORANDUM NEW YORK CITY OFFICE 767 THIRD
THE KUGLER SYSTEM ESTATE CONCEPTS TECHNIQUE BOOK TABLE OF CONTENTS Review of Important Terms and Concepts Chapter I: The Proposed Estate Strategy Simple Will Arrangement (assuming Mr. Kugler Predeceases
Portability of the Deceased Spousal Unused Exclusion Amount under the Tax Relief Act of 2010 Bryon W. Harmon Shipman & Goodwin LLP firstname.lastname@example.org Connecticut Bar Association Estates & Probate Section
THE WEALTH COUNSELOR LLC Irrevocable Life Insurance Trust (ILIT) What Is the Irrevocable Life Insurance Trust? An irrevocable trust is one in which the grantor completely gives up all rights in the property
Irrevocable Life Insurance Trusts: Perhaps the Best Kept Secret in Tax Savings A. Jude Avelino * Life insurance is protection against the death of an individual in the form of payment to a beneficiary,
Living Trust Overview TABLE OF CONTENTS WHAT IS PROBATE AND WHY DO YOU WANT TO AVOID IT? 2 THE HIGH COST OF DYING 2 A REVOCABLE LIVING TRUST ELIMINATES PROBATE 3 HOW A LIVING TRUST WORKS 3 REVOCABLE LIVING
The Basics of Estate Planning Introduction The process of estate planning can be a daunting prospect. Often individuals will avoid the process altogether. Obviously, this is not the best approach since
product resource Taking Advantage of the New Gift and Estate Tax Law summary tra 2010 in brief Congressional debate about whether to extend tax cuts put into place during the Bush administration came to
Todd M. Villarrubia Attorney at Law, LL.M. in Taxation Board Certified Expert in Estate Planning 101 W. Robert E. Lee Blvd., Suite 404, New Orleans, LA 70124 Tel 504.212.3440 Fax 504.324.0936 email@example.com
Estate Tax Concepts for Edward and Tina Collins Joseph Davis, CLU, ChFC 215 Broad Street Charlotte, North Carolina 26292 Phone: 704-927-5555 Mobile Phone: 704-549-5555 Fax: 704-549-6666 Email: firstname.lastname@example.org
Tax Effective Cross-Border Will Planning Martin Rochwerg Partner Federated Press Cross-Border Personal Tax Planning February 27-28, 2012 DISCLAIMER 1. We are not U.S. lawyers or tax advisors. 2. This presentation
Estate Planning Made Simple: A Primer for Gift and Estate Tax Scott Hubbard Wealth Management Thomas Jefferson School of Law Summer 2008 TABLE OF CONTENTS Introduction... 1 Discussion... 2 I. Gift Tax...
IRREVOCABLE LIFE INSURANCE TRUST OPERATING GUIDE Law Office of Robert J. Mondo P.O. Box 72668 Roselle, Illinois 60172 (630) 215-3676 Fax (630) 894-8860 E-mail: email@example.com Website: www.lawrjm.com This
Law Offices of Robert J. Ross 1622 W. Colonial Parkway, Suite 201 (847) 358-5757 Inverness, Illinois 60067 Fax (847) 358-7088 Bob@RobertJRoss.com ESTATE PLANNING Estate planning is more than simply signing
Does the American Taxpayer Relief Act Eliminate the Need for Credit Shelter Trusts? By: George L. Schoenbeck, Sosin & Arnold, Ltd. Regardless of their areas of focus, most lawyers find themselves working
December 2010 Special Edition A monthly report for wealth management professionals. Edited by Henry J. Leibowitz As part of our ongoing efforts to keep wealth management professionals informed of recent
Ticking Time Bombs in Irrevocable Life Insurance Trusts Written by: Thomas W. Abendroth firstname.lastname@example.org 312.258.5501 Originally published in Trusts & Investments. March 2008 One Atlantic Center,
When an Irrevocable Trust Is Not: Giving New Life to Insurance Trusts by Kevin B. Rack Must have independent trustee Take advantage of annual exclusion of $14,000 per beneficiary Requires annual letterwriting
By Melvin A. Warshaw ILITs and the GST Tax: How Do We Fund Premiums in 2010? For some insureds, legislative uncertainty doesn t require much of an adjustment to funding of their irrevocable life insurance
A Sole Proprietor Insured Buy-Sell Plan At a sole proprietor s death, the business is dissolved and all business assets and liabilities become part of the sole proprietor's personal estate. Have you evaluated
THE LAW OFFICE OF JEFFREY M. JANEIRO, P.L. 5621 STRAND BLVD., SUITE 101 NAPLES, FLORIDA 34110 TEL. (239)-513-2324 FAX. (239)-513-9580 www.janeirolaw.com The Value of Using Irrevocable Trusts in Medicaid
CESAs Coverdell Education Savings Accounts Questions & Answers What is a Coverdell Education Savings Account? A Coverdell Education Savings Account is a type of tax-preferred savings and investment account
Part III Administrative, Procedural, and Miscellaneous 26 CFR 601.201: Rulings and determination letters. (Also: Part I, 170, 642(c), 2055, 2522; 1.170A-6, 20.2055-2, 25.2522(c)-3) Rev. Proc. 2007-45 SECTION
Estate Planning For Everyone Boston College Shaw Society Boston College Alumni Association November 20, 2013 Michael J. Puzo, Esq. Hemenway & Barnes LLP 60 State Street Boston, Massachusetts 02109 617-557-9721
IDEAS February 2012 Make Big Gifts to a Dynasty ILIT Summary Make big gifts to a dynasty trust and the assets will be out of the transfer tax system forever. Use life insurance for an even more effective
STRATEGIC THINKING The New Tax Relief Act: How Will You Be Impacted? The President signed the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 ( the Act ) on December 17th,