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Estate Planning and Tax Reform: Wealth Transfer Structures Under the New Tax Law

Note: CPE credit is not offered on this program

Recording of a 90-minute CLE webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Tuesday, February 5, 2019

Recorded event now available

or call 1-800-926-7926

This CLE course will provide estate planning counsel and advisers with a critical look at the practical impact of the newly enacted tax overhaul/reform legislation. The panel will detail specific provisions of the new law relevant to estate planning and offer concrete guidance for estate planners and fiduciaries to achieve beneficial tax results and avoid potential pitfalls arising from changes to estate and trust tax treatment.


The new tax reform law represents the most sweeping changes to the U.S. income tax code in over 30 years, changes that will impact virtually every aspect of American society. For estate planning counsel and advisers, the new law creates significant challenges in wealth transfer strategy and emphasis.

The law alters some critical provisions in the estate and wealth transfer tax system. By doubling the amount exempt from estate tax, tax reform provides transfer tax planning opportunities, and also requires estate planning advisers to focus more than ever on income tax minimization on the transfer of accumulated assets.

The law's impact on estate and wealth transfer planning will likely yield unexpected results. Because many of its most far-reaching provisions are scheduled to sunset in 2025 (unless extended by a future Congress), planners face significant uncertainty in constructing long-range estate plans. Further complicating matters for estate advisers is the likelihood that some states will keep lower estate tax exemptions than the new federal amount. Planners will need to structure wealth transfer plans that take state estate and gift taxes into account while planning within the federal framework.

An additional challenge for planners will be reconciling past transactions and structures to the framework of the new law. The IRS has provided only limited guidance on how it will apply the new exemption amounts to prior reporting of taxable gifts that exceeded the previous exemption amount.

Likewise, specific existing wealth transfer structures may not be tax-efficient under the new provisions. Estate planning advisers need to have a thorough grasp of the permanent and non-permanent changes to wealth transfer taxes brought about by the new law.

Listen as our authoritative panel provides a critical first look at the wealth transfer implications of the new tax reform law.



  1. Wealth transfer regime provisions in the new tax law
  2. Tax planning
    1. Steps in light of a Dec. 31, 2025 sunset provision
    2. Where no changes in the generation-skipping transfer tax
    3. For states with much lower estate tax exemptions
    4. To maximize income tax basis step-up opportunities


The panel will review these and other high priority issues:

  • Key provisions and changes in the tax reform act for estate planning
  • Structuring wealth transfer vehicles in light of Dec. 31, 2025 sunset provision
  • Designing estate and wealth transfer plans in states with lower estate tax exemptions than the new federal rate
  • Reconciling past transactions and structures to correspond to the framework of the new law
  • Planning to maximize income tax basis step-up opportunities


McCall, Jennifer
Jennifer J. McCall

Pillsbury Winthrop Shaw Pittman

Ms. McCall chairs the Estates, Trusts & Tax Planning practice and is a leading authority on U.S. and international...  |  Read More

Willis, Tyson
Tyson D. Willis

Arnall Golden Gregory

Mr. Willis focuses his practice on crafting and implementing successful wealth transfer planning strategies, including...  |  Read More

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