Schlapfer v. Commissioner, T.C. Memo. 2023-65 (U.S. Tax Court May 22, 2023), is the first reported case to contain a detailed discussion of the adequate disclosure requirements under the gift tax adequate disclosure regulations that are set forth in Treas. Reg. Sec. 301.6501(c)-1(f).

After years of debate, discussion and indecision over income gaps, some states have proposed laws to tax the uber-rich even as President Biden calls for the same. Is America ready to cross this threshold of taxation? And what’s really behind the threats and the promises?

For decades, most people have known 529 Plans  as a tool for putting money aside tax free for their children’s college expenses. Less known is their usefulness as a powerful estate planning tool. Strategically, using 529s as part of a wealth transfer strategy can help high-net-worth clients pass on significant wealth tax free to future generations. 

There are two separate significant IRS challenges to grantor retained annuity trusts (GRATs) in the context of ongoing merger negotiations that have garnered considerable attention going back to 2019. 

The last two articles the author wrote, Dealing with Proposed Regs under the SECURE Act and Strategy Under the SECURE Act, examined certain strategic issues that CPAs may need to explain to their clients. This article assumes the reader knows those concepts as a base and complements those ideas with planning for long-term second marriages and for trying to minimize fiduciary income tax on IRAs held in trust without necessarily getting IRA distributions out of trust.   

Although horrifying tales of on-line romance scam artists swindling the life savings of the lonely are being highlighted on the airwaves, seeing how the love life of a client or his or her children can devastate well-established family businesses is more terrifying—and pervasive.

The Heart Act added a new federal  Inheritance Tax on certain lifetime and testamentary dispositions to U.S. recipients, made by a “covered expatriate.” This is the second article in our two-part series on the expatriation tax. (To view the first article, please click here.)