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Tag Archives: Revenue Ruling 85-13
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
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Tax News & Comment — February 2014
Posted in Tax News & Comment
Tagged 1031, applicable exclusion amount, carryover basis, Congress, credit shelter trust, doma, estate planning, estate tax, Health Insurance Regulations, Medicare Tax, new york estate tax, New York Trust Fiduciaries, New York Trustees, President Obama, Revenue Ruling 85-13, Trustee Commissions, Windsor v. United States
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INSTALLMENT SALES OF ASSETS TO GRANTOR TRUSTS
Installment sales of assets to irrevocable grantor trusts is one of the most powerful estate planning techniques available today. Sales to “intentionally defective” irrevocable grantor trusts capitalize on different definitions of “transfer” for income and transfer tax purposes. Following such a sale, the grantor reports income tax on trust income. However, the grantor no longer owns the assets for gift and estate tax purposes. Therefore, the trust assets (and appreciation) will be removed from the grantor’s gross estate. Assets sold to the trust may consist of stock in a closely held business, real estate, marketable securities, or limited partnership interests. The trust may even hold S Corporation stock without jeopardizing the election. Continue reading
From Washington & Albany — Income & Estate Tax Planning in 2015
I. From Washington Income tax planning in 2015 will seek to reduce the effect of high federal and New York tax rates. Avoidance of unnecessary capital gain realization through basis increases or nonrecognition transactions will remain important. Estate tax planning … Continue reading →