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Category Archives: Estate Planning
IRS & NYS DTF Matters; Recent Developments & 2014 Regs. & Rulings of Note
I. New York State Matters NYS Amends Estate & Gift Tax Beginning April 1, 2014, the NYS estate exemption will increase every 12 months through 2017. On April 1, 2014, the NYS exemption became $2.0625; on April 1, 2015, $3.125 … Continue reading
Posted in Estate Planning, Federal Gift Tax, Federal Income Tax, Grantor Trusts, Income Taxation of Nongrantor trusts, Portability
Tagged asset sales to grantor trusts, final regs on portability, final regs on section 67(a), last deceased spouse, new york "throwback" rule for trusts, New York Amendments to Gift and Estate Tax, New York estate tax exemption, new york obviates grantor trusts, New York portability, new york trust changes, new york's "cliff" estate rule, plr 20130002 new york, Portability, qtip contingency plr 20140011, relief from late portability elections, Taylor v. NYS Tax Commission
The Evolution of Trusts in American Jurisprudence
I. Introduction A trust is a relationship whereby a trustee holds property for the benefit the beneficiary, or cestui que trust. A division of ownership occurs between the trustee, who holds legal title, and the beneficiary, who holds equitable title. … Continue reading
Posted in The Evolution of Trusts in American Jurisprudence, Treatises, Trusts
Tagged bailment, cestui que trust, common law of england, courts of chancery, english courts of law, equitable charge, fiduciaries, HEMs standard, history of trusts, justice cardozo, justice story, king v. talbot, king's courts of law, meinhard v. salmon, merger of law and equity, no further inquiry rule, prudent investor rule, treas. reg. 301.7701-4(a), trust beneficiary, trust distinguished from contract, trusts distinguished from other legal forms, uniform trust code
Taxation of Foreign Nongrantor Trusts: Throwback Rule
I. Introduction The throwback rule is intended to prevent a foreign trust from accumulating income, thereby delaying the reporting of that income by U.S. beneficiaries until the time when the income is eventually distributed. The throwback rules defeat this income … Continue reading
Income Taxation of Nongrantor Trusts
Posted in Income Taxation of Nongrantor trusts, Income Taxation of Nongrantor trusts, Income Taxation of Nongrantor trusts, News
Tagged carry out DNI, complex trusts, distributable net income, distribution deduction, fiduciary accounting income, fiduciary income tax return, nongrantor trusts, simple trusts, subchapter j, taxation of trusts, tentative taxable income, tier one distributions, tier rules, tier two distributions, Trustee Commissions
Rev. Rul. 85-13: Is There a Limit to Disregarding Disregarded Entities?
I. Introduction Although the federal estate tax is not extinct, with the combined marital exemption now north of $10 million, it is an endangered species. Recently, Governor Cuomo signaled his intent — likely to be affirmed by State Republicans — … Continue reading
Posted in Asset Sales to Grantor Trusts, Estate Planning
Tagged defective grantor trusts, disregarded entities, estate planning, federal estate tax exemption, grantor trusts, IRC section 675, irc section 675(4)(C), nongrantor trust, nys estate tax, Portability, qprts purchase residence, Revenue Ruling 85-13, sales to defective grantor trusts, sales to grantor trusts, substitution power
Estate Planning in 2013
Posted in Estate Planning, Estate Planning in 2013, Estate Planning in 2013, News, Treatises
Tagged applicable exclusion amount, carryover basis, completed gift, Congress, estate planning, estate tax, form 709, gift tax, gross estate, GST, marital deduction, new york estate tax, QTIP, QTIP election, surviving spouse, tax planning
August Comment: NYS Estate, Gift & Trust Tax Update
I. Introduction A number of important changes to New York estate, trust and gift tax law were recently enacted. Briefly, (i) the New York estate tax exemption will reach parity with the federal exemption by 2019; (ii) the federal estate … Continue reading →