Whitworth: PA Inheritance Tax Rate Reduced to 0% for Parent to Child 21 and Under

On June 28, 2019, Pennsylvania Governor Tom Wolf approved HB 262, which effectively reduces the inheritance tax rate to 0% so long as the property is transferred from a parent — whether natural, adoptive, or step — or transferred for the benefit of a child age 21 or under.  Presumably, reporting requirements will remain the … Continue reading Whitworth: PA Inheritance Tax Rate Reduced to 0% for Parent to Child 21 and Under

PLR 201928003: Code Sec. 7520 – Terminal Taxpayer May Use Special Actuarial Factor for Gift Valuation

In PLR 201928003 the IRS ruled that a terminal taxpayer may use a special actuarial factor to value certain gifts made by her during her lifetime. The facts were as follows: Taxpayer was born on Date 1. Taxpayer is the income beneficiary of three trusts. On Date 2, Taxpayer utilized the disclaimer provisions expressly provided … Continue reading PLR 201928003: Code Sec. 7520 – Terminal Taxpayer May Use Special Actuarial Factor for Gift Valuation

PLR 201928004: Ruling on Proposed Trust Division

In PLR 201928004, the IRS ruled on a proposed division of a trust into subtrusts. The PLR made the following rulings:  1. The Proposed Division of Trust into the Subtrusts and the pro rata allocation of the assets of Trust among the Subtrusts will not cause Trust or any of the Subtrusts to lose its … Continue reading PLR 201928004: Ruling on Proposed Trust Division

PLR 201928005: Tax Consequences of Charitable Lead Annuity Trust (CLAT) Termination

In PLR 201928005 the IRS ruled on tax consequences of the termination of a CLAT. Here, a decedent's estate was transferred from a charitable lead annuity trust (CLAT) to a charitable foundation after decedent's death pursuant to decedent's will. The CLAT paid annual annuity payments to the foundation. The CLAT requested a state court order … Continue reading PLR 201928005: Tax Consequences of Charitable Lead Annuity Trust (CLAT) Termination

Joint Committee on Taxation Description of President Trump’s FY 2020 Budget Recommendations, including Proposal to Make Permanent Individual Tax Provisions, Including Estate & Gift Tax Provisions

The Joint Committee on Taxation has made available it's description of revenue provisions in President Trump's FY 2020 Budget Proposal. These include the proposal to make permanent the individual tax provisions that sunset for tax years beginning on or after January 1, 2026, including the estate and gift tax provisions, among others. To see the … Continue reading Joint Committee on Taxation Description of President Trump’s FY 2020 Budget Recommendations, including Proposal to Make Permanent Individual Tax Provisions, Including Estate & Gift Tax Provisions

CCA 201926013: Alternate Valuation Date Disallowed

In Chief Counsel Advice 201926013, the IRS concluded that where the audit determined that estate and GST taxes on the decedent's date of death were lower than on the alternate valuation date, an executor who elected to use an alternate valuation date could not use that date, but had to use the date of death … Continue reading CCA 201926013: Alternate Valuation Date Disallowed