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Estate and Gift Taxation Current Developments: Rev Ruling 2023-2's Impact on Grantor Trusts, CTA Reporting

Note: CLE credit is not offered on this program

A live 110-minute CPE webinar with interactive Q&A

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Wednesday, June 5, 2024 (in 12 days)

1:00pm-2:50pm EDT, 10:00am-11:50am PDT

or call 1-800-926-7926

This webinar will address the latest developments in gift and estate taxation, including beneficial ownership information reporting requirements under the Corporate Transparency Act, 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

The Corporate Transparency Act requires certain business entities to report beneficial owners to FinCEN. These reporting requirements extend to trusts that hold interests in business entities which could create an obligation to report personal identifying information for executors, trustees, and beneficiaries. Failure to file penalties can amount to as much as $10,000. Willful failure to file a return is a criminal offense.

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. Corporate Transparency Act
  3. Revenue Ruling 2023-2
  4. Revenue Procedure 2022-32: Extension of Time to File Portability Election
  5. Cecil v. Commissioner and valuation discounts
  6. Proposed regulations
    1. Exceptions to anti-clawback rules
    2. Administrative expenses, claims against an estate, interest expense
  7. Cryptocurrency and digital assets in estates
  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?
  • Which trusts are subject to reporting requirements of the Corporate Transparency Act?
  • 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

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

Additional faculty
to be announced.
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