The Tax Rules Were Never Friendlier, But Changes May be on the Way The biggest loophole in the tax code may soon be coming to an end—at least according to the messages sent by the Obama administration and its recent budget proposals. The American Taxpayer Relief Act of 2012 (ATRA) set a whole new tone for most estate plans when it took the dreaded estate tax off the table. However, it is no secret that the IRS has been making a concerted effort to recapture some of the revenues lost from property transfers by way of gift or upon death.…
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Estate Planning When the Federal Estate Tax Doesn’t Apply Even when your clients have estates that will not be subject to the federal estate tax when they die, helping them plan for the future can be complicated. Steven G. Siegel, JD, LLM, Siegel Group, suggests ways you can help them best manage their assets To read the full article in AICPA Insights, click: Estate Planning for the 99 Percent.
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Use of Synthetic Credit Ratings to Determine the Appropriate Market Yield for the Preferred Equity Interest Among the estate tax planning methods that include grants of “carried” or profit interests, grantor retained annuity trusts, outright gifts, etc., entity freeze is a less known, or perhaps, less utilized tool. Yet, in certain circumstances, a freeze entity can be a compelling wealth transfer mechanism. This article presents an overview of a freeze entity structure, its economics, and a valuation framework specific to freeze entities. The article also offers an example of how practitioners can deal with an important element of the freeze…