2021 GST Tax Planning: Applicable Rules, Allocations, Formula Drafting, Key Challenges, and Mistakes to Avoid
Note: CPE credit is not offered on this program
Recording of a 90-minute CLE video webinar with Q&A
This CLE course will provide estate planners guidance on key generation-skipping transfer (GST) tax planning techniques under current tax law and proposed tax law changes. The panel will discuss applicable GST rules and utilizing those rules to the advantage of clients, allocations, formula drafting, and more. The panel will also discuss reporting requirements, computing the GST tax, key challenges, and mistakes to avoid.
Outline
- IRC 2642 structure
- Inclusion ratio defined
- Applicable fraction defined
- Treatment of inclusion ratios in severance of GST-impacted trust into two or more trusts
- Special rules for CLATs and other trusts
- Calculation of inclusion ratio
- Planning implication of pre-transfer inclusion ratio and fraction calculations
- Utilizing GST tax planning in light of potential tax law changes
Benefits
The panel will review these and other important topics:
- What are the key planning considerations in light of potential tax law changes?
- How can GST tax planning assist clients under current tax law and in anticipation of tax law changes?
- How do you spot trusts with an inclusion ratio greater than zero?
- What is the interrelation between inclusion ratio and an applicable fraction under Section 2642 and its regulations?
- What are the special rules for CLATs and other types of trusts in calculating the inclusion ratio and imposition of GST tax?
Faculty
Jennifer A. Mendel
Partner
Barnes & Thornburg
Ms. Mendel has spent the last 15 years honing her craft counseling high net worth families on complex trust, estate and... | Read More
Ms. Mendel has spent the last 15 years honing her craft counseling high net worth families on complex trust, estate and family office planning. She is a strong communicator who is skilled at listening to her clients – learning about their lives, business ventures and family needs – and helping them tailor a plan to achieve their goals.
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Matthew E. Rappaport, Esq., LL.M.
Vice Managing Partner
Falcon Rappaport & Berkman
Mr. Rappaport chairs FRB’s Taxation and Private Client Groups. He concentrates his practice in Taxation... | Read More
Mr. Rappaport chairs FRB’s Taxation and Private Client Groups. He concentrates his practice in Taxation as it relates to Real Estate, Closely Held Businesses, Private Equity Funds, Family Offices and Trusts & Estates. He advises clients regarding tax planning, structuring, and compliance for commercial real estate projects, all stages of the business life cycle, generational wealth transfer, family business succession, and executive compensation. Mr. Rappaport also collaborates with other attorneys, accountants, financial advisors, bankers, and insurance professionals when they encounter matters requiring a threshold level of tax law expertise. He is known for his work on complex deals involving advanced tax considerations, such as Section 1031 Exchanges, the Qualified Opportunity Zone Program, Freeze Partnerships, Private Equity Mergers & Acquisitions, and Qualified Small Business Stock. Mr. Rappaport has served as a trusted advisor for prominent real estate funds, executives of multinational corporations, venture capitalists, successful startup businesses, ultra-high net worth families, and clients seeking creative solutions to seemingly intractable problems requiring tax-focused analysis.
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