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Estate and Gift Taxation Current Developments: Connelly v. IRS, Rev Ruling 2023-2's Impact on Grantor Trusts

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Friday, June 28, 2024

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This webinar will address the latest developments in gift and estate taxation, including the SCOTUS decision in Connelly v. United States, Revenue Ruling 2023-2's impact on grantor trusts and basis step-up, the continuing impact of the sunset of the lofty estate tax exclusion, and other recent legislation. Our panel of generational wealth experts will explain which estates are impacted by recent changes and offer planning tips to minimize related transfer taxes.

Description

June 2024, the Supreme Court issued a landmark decision in Connelly v. United States siding with the Internal Revenue Service. It determined that life insurance proceeds should be included a business valuation, and hence an estate, when a company has a buy sell agreement in place that is triggered by the death of a shareholder. The decision has major implications for estate planning for business owners.

The April 2023 IRS Bulletin summarized Revenue Ruling 2023-2 by stating that the Ruling "confirms that the basis adjustment under section 1014 generally does not apply to the assets of an irrevocable grantor trust not included in the deceased grantor's gross estate for Federal estate tax purposes," thus challenging the use of IDGTs (intentionally defective grantor trusts), which have been a historically valuable estate planning tool. Continuing to develop are planning opportunities surrounding the impending reversion of the estate tax exclusion to 2017 amounts.

Listen as our panel of transfer tax experts reviews the latest developments in estate and gift tax for trust and estate professionals.

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Outline

  1. Current developments in estate and gift taxation: introduction
  2. Revenue Ruling 2023-2
  3. Revenue Procedure 2022-32: Extension of Time to File Portability Election
  4. Connelly v. United States
  5. CCA 202352018 – Grantor trust reimbursements
  6. Cecil v. Commissioner and valuation discounts
  7. Proposed regulations
    1. Exceptions to anti-clawback rules
    2. Administrative expenses, claims against an estate, interest expense
  8. Other developments

Benefits

The panel will explore these and other critical issues:

  • Which estates are eligible for the extensions of time to elect portability under Rev Proc 2022-32?
  • How Connelly v. United States impacts estate planning for business owners
  • What transfers are considered de minimis and not subject to the exceptions to the anti-clawback regulations?
  • How Revenue Ruling 2023-2 impacts grantor trusts

Faculty

Alt, Justin
Justin D. Alt
Counsel
Willkie Farr & Gallagher

Mr. Alt is counsel in the Private Clients Group, based in Los Angeles. A trusts and estates attorney with a strong...  |  Read More

Edmondson, S. Gray
S. Gray Edmondson
Partner
Edmondson Sage Allen

Mr. Edmondson practices in partnership, corporate, and individual tax planning; business transactions including mergers...  |  Read More

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