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Tax Issues and IRS Guidance for Irrevocable Grantor Trusts

A live 90-minute CLE/CPE video webinar with interactive Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
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Thursday, August 21, 2025

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Early Registration Discount Deadline, Friday, July 25, 2025

or call 1-800-926-7926

This CLE/CPE webinar will provide guidance on common tax issues for irrevocable grantor trusts encountered by trust and estate advisers, including recent IRS guidance for basis adjustments and other basis issues. The panel will discuss options and key provisions in structuring trusts, Revenue Ruling 2023-2 and its impact on basis and estate and tax planning, determining and substantiating tax basis, planning considerations for U.S. persons, and other tax issues and basis conundrums encountered by estate and trust advisers.

Description

The significant increase in the federal estate tax exemption under current tax law emphasizes the need for estate planners to minimize income taxes for beneficiaries on assets passed through inheritances and trusts. Revenue Ruling 2023-2 provides guidance regarding the tax basis for assets for certain trusts for federal income tax purposes passing from a decedent upon the owner's death and other key issues. Estate planners and advisers must have a complete understanding of current tax rules and IRS guidance and their potential impact on estate and tax planning.

As fewer estates are subject to estate or gift tax, planners and fiduciary advisers must focus on managing tax basis to minimize the tax cost of transferring assets to beneficiaries. Section 1014 allows inheritors to step up the tax basis of assets, which may reduce capital gains taxes. The basis consistency rules allow the IRS to assess penalties under Section 6662 against the estate or beneficiary for basis reporting inconsistencies stemming from valuations aimed at eliminating income taxes. This accuracy-related penalty for the underpayment of tax resulting from a valuation misstatement can be costly for estates and beneficiaries.

Estate planners must ensure that any valuation of assets for the purpose of achieving a step-up in basis adheres to the tax basis rules under current law and recently issued Revenue Ruling 2023-2. Estate planning advisers must also consider other options such as gift planning techniques, transfers of assets, and the use of trusts to obtain a step-up in basis and avoid the severe consequences of a misstep.

Listen as our panel discusses options and key provisions in structuring trusts, Revenue Ruling 2023-2 and its impact on basis and estate and tax planning, determining and substantiating tax basis, planning considerations for U.S. persons, and other tax issues and basis conundrums encountered by estate and trust advisers

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Outline

  1. Revenue Ruling 2023-2
  2. Challenges for taxpayers with irrevocable trusts
  3. Identifying low basis assets subject to potential income tax consequences
  4. Transfer strategies
  5. Post-mortem tools for achieving income tax basis step-up
  6. Potential tax risks of basis adjustment strategies

Benefits

The panel will review these and other important topics:

  • Impact of Revenue Ruling 2023-2 on taxpayers with irrevocable trusts
  • Reevaluating income tax planning and alternative options for completed gift grantor trusts
  • Which class of assets benefit from basis adjustment transactions?
  • Using trust decanting and other post-mortem actions to achieve basis step-up
  • Structuring sale and exchange transactions between trusts to maximize tax basis
  • Tax and other risks involved in basis adjustment transactions and strategies

Faculty

DiPietro, Samuel
Samuel M. DiPietro

Associate
Spencer Fane

Mr. DiPietro collaborates with families and their advisors to create customized estate plans that consider the specific...  |  Read More

Alex Kurutz
Alex Kurutz

Tax Manager
RSM US

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 |  Read More
Attend on August 21

Early Discount (through 07/25/25)

See NASBA details.

Cannot Attend August 21?

Early Discount (through 07/25/25)

You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.

To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Video