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In August of 2016, the IRS issued long awaited proposed regulations under IRC Section 2704. If adopted, these proposed regulations may significantly reduce the opportunity to apply valuation discounts when making intra-family transfers of interests in various entities. For estate planning attorneys and their clients this translates to impending restrictions […]

It seems lately that as soon as Halloween ends, the holiday season begins and we all look forward to the end of the past year and the beginning of a new, and hopefully, wonderful exciting one. The air grows colder, the leaves are gone, and the days seem so short. […]

On August 29, 2013, the IRS issued an announcement (Rev. Rul. 2013-72 http://www.irs.gov/pub/irs-drop/rr-13-17.pdf ) ruling that it will treat same-sex couples, legally married in jurisdictions that recognize their marriages, as married for federal tax purposes. Importantly, the ruling applies regardless of whether the couple lives in a jurisdiction that recognizes same-sex marriage or a jurisdiction that does not recognize same-sex marriage.

On December 17, 2010, Congress enacted what we know as the 2010 Tax Act, changing the estate, gift and generation-skipping transfer (“GST”) tax regime. Before the passage of the Act, the federal estate tax exemption – the amount that an individual can pass to his or her beneficiaries tax-free – increased in steps from $675,000 per individual in 2001 to, ultimately, $3.5 million per individual in 2009. In 2010, the federal estate tax was eliminated; but only temporarily. Under prior law, the federal estate tax was scheduled to return in 2011 with a maximum tax rate of 55 percent and a $1 million exemption, meaning that if a decedent’s estate exceeded $1 million, such excess would be taxed at a 55 percent rate.