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Wealth Transfer Tax Summary (64 pp) (relevancy score: 100%)

by Jeffrey N. Pennell
from Estate and Gift Tax: Essential Elements (August 29, 2012)

The personal representative's alternative approaches to valuation and claiming the loss for income and estate tax purposes include (1) inclusion at the date of death value of the automobile and deduction of the loss for estate tax purposes under §2054, (2) inclusion at the date of death value and deduction for income tax purposes under §165, or (3) inclusion at the alternate value. Under alternate valuation, changes due to the mere lapse of time (for example, a life estate that becomes less ...

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ARTICLE: On the Brink Once More (10 pp) (relevancy score: 100%)

by Ronald D. Aucutt
from The New Estate Tax Regime: Making Sense out of Chaos (December 22, 2010)

Targeted Relief for Real Estate The Baucus Bill would have provided substantial estate tax relief for real estate. Section 302(a) establishes an estate tax applicable exclusion amount, or "exemption," of $5 million and a top estate tax rate of 35 percent, effective January 1, 2010. The GST Tax The GST tax exemption and rate will remain tied to the estate tax applicable exclusion amount and top rate, just as they have been since 2004.

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AMENDMENT: Senate Amendment to House Amendment to Senate Amendment (S. Amdt. 4753 to H.R. 4853) (8 pp) (relevancy score: 100%)

by
from The New Estate Tax Regime: Making Sense out of Chaos (December 22, 2010)

--For purposes of this section, the applicable credit amount is the amount of the tentative tax which would be determined under section 2001(c) if the amount with respect to which such tentative tax is to be computed were equal to the applicable exclusion amount. --For purposes of this subsection, the applicable exclusion amount is the sum of-- "(A) the basic exclusion amount, and "(B) in the case of a surviving spouse, the deceased spousal unused exclusion amount. (3) Section 6018(a)(1) is...

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TECHNICAL EXPLANATION: The Revenue Provisions Contained in the 'Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010' Scheduled for Consideration by the U.S. Senate (180 pp) (relevancy score: 100%)

by
from The New Estate Tax Regime: Making Sense out of Chaos (December 22, 2010)

2 A. Marginal Individual Income Tax Rate Reductions (sec. 101 of the bill and sec. 1 of the Code)...................................................................................................................... 29 J. Child Tax Credit (sec. 103 of the bill and sec. 24 of the Code) ..................................... 32 K. Increase in the Earned Income Tax Credit (sec. 103 of the bill and sec. 32 of the Code) ...

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Where Are We on Federal Estate Tax, Federal Generation Skipping Transfer Tax, and Basis Issues in This Chaotic or Limbo State? (16 pp) (relevancy score: 100%)

by Anita J. Siegel
from Administering the 2010 Decedent's Estate (REPLAY with e-mail Q & A) (December 16, 2010)

Although at this time we have no federal estate tax and no federal generation skipping tax for decedents dying in 2010 and gifts made in 2010, we still have the federal gift tax and federal and New Jersey income tax. We also still have the New Jersey inheritance tax and the New Jersey estate tax applying to estates of decedents dying in 2010 (with reference to the FET on 12/31/01 for the New Jersey estate tax) even though there is no current federal estate tax. Note: NJ uses the federal ...

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Human Issues in Estate Planning for the Closely Held Business (40 pp) (relevancy score: 100%)

by Lauren J. Wolven, Esquire
from Advanced Estate Planning Techniques for Family Owned and Closely Held Businesses (December 8, 2010)

2 Advanced Estate Planning Techniques for Family Owned and Closely Held Business ALI-ABA September 13, 2010 Webcast Course Human Issues in Estate Planning for the Family Owned and Closely Held Business Lauren J. Wolven, J.D.1 Prior to October 1, 2010 Horwood Marcus & Berk Chtd. 924586/1/88888.LWOLVEN 3 Advanced Estate Planning Techniques for Family Owned and Closely Held Business ALI-ABA September 13, 2010 Human Issues in Estate Planning for the Family Owned and Closely Held Business By ...

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Mom and Pop Want to Retire on a Full Salary – How Can the Company Afford To Do It? (50 pp) (relevancy score: 100%)

by Donald O. Jansen, Esquire
from Advanced Estate Planning Techniques for Family Owned and Closely Held Businesses (December 8, 2010)

35 4. Is the Restricted Access Executive Bonus Plan a pension benefit plan rather than a welfare benefit plan under ERISA? ............................................... C. Qualified Plans Expensive For may closely-held companies, nonqualified deferred compensation plans are the only means of deferring compensation for the top executives. An "excess benefit plan" is a defined benefit plan which provides benefits to executives in excess of the IRC Section 415 or compensation limits on ...

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Tools and Techniques for Transferring the Business to the Next Generation (154 pp) (relevancy score: 100%)

by Ronald D. Aucutt
from Advanced Estate Planning Techniques for Family Owned and Closely Held Businesses (December 8, 2010)

Use of Grantor Retained Annuity Trusts (GRATs) .................................................... A sale to a grantor trust also capitalizes on the lack of symmetry between the income tax rules governing grantor trusts and the estate tax rules governing includibility in the gross estate. - 4 - 99 C. GRATs as Grantor Trusts 1. Benefits of qualifying as a grantor trust.

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The Important Role of Life Insurance in the Closely Held or Family Owned Business (26 pp) (relevancy score: 100%)

by Charles L. Ratner
from Advanced Estate Planning Techniques for Family Owned and Closely Held Businesses (December 8, 2010)

Many policies distinguish between the "current premium" and "maximum guaranteed premium," which the company will specify in the policy. F. No-Lapse Universal Life 1. The no-lapse universal life policy, also known as "guaranteed UL", allows the policy owner to lock-in a premium that is guaranteed to support the death benefit. G. Variable Universal Life 1. Like its general account sibling universal life, variable universal life (VUL) is a flexible premium policy that allows the policyholder ...

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Memorandum re: December Section 7520 Rate (4 pp) (relevancy score: 100%)

by Lawrence P. Katzenstein
from Charitable Planning in a Time of Low Interest Rates (December 8, 2010)

CHARITABLE LEAD ANNUITY TRUSTS A charitable lead annuity trust is in many ways the opposite of a charitable remainder annuity trust: the trust provides for payment of an annuity interest to charity, typically for a term of years, with the remainder payable to other family members. The income tax deduction for charitable gift annuity donors as well as donors to charitable remainder annuity trusts will be dramatically reduced. In addition, the unusually low interest rate creates certain traps...

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Drafting Charitable and Lead Trusts and a Look at the IRS Lead (22 pp) (relevancy score: 100%)

by Lawrence P. Katzenstein
from Charitable Planning in a Time of Low Interest Rates (December 8, 2010)

Since most charitable lead trusts will be annuity trusts and since most lead trustswill be for a term of years, the examples assume term of years annuity trusts. 2007-45 and46 are, respectively, inter vivos charitable lead annuity trusts (both grantor and non-grantor type)and a testamentary charitable lead annuity trust. The sample intervivos non-grantor charitable lead annuity trust is straightforward and does nothave the interesting grantor trust issues of the grantor lead trust.

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A Guide to the IRS Sample Charitable Remainder Trust Forms (16 pp) (relevancy score: 100%)

by Richard L. Fox
from Charitable Planning in a Time of Low Interest Rates (December 8, 2010)

28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Document Outline A Guide to the IRS Sample Charitable Remainder Trust Forms 3. A Guide to the IRS Sample Charitable Remainder Trust Forms

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Early Termination of Charitable Remainder Trust (4 pp) (relevancy score: 100%)

by Richard L. Fox
from Charitable Planning in a Time of Low Interest Rates (December 8, 2010)

44 45 46 Document Outline Early Termination of Charitable Remainder Trust 4. Early Termination of Charitable Remainder Trust

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Low Section 7520 Rates Present Charitable Planning Opportunities (2 pp) (relevancy score: 100%)

by Richard L. Fox
from Charitable Planning in a Time of Low Interest Rates (December 8, 2010)

48 Document Outline Low Section 7520 Rates Present Charitable Planning Opportunities 5. Low Section 7520 Rates Present Charitable Planning Opportunities

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IRS Approves Rescission of CRAT That Failed 10% Requirement (8 pp) (relevancy score: 100%)

by Richard L. Fox
from Charitable Planning in a Time of Low Interest Rates (December 8, 2010)

50 51 52 53 54 55 56 2 Document Outline IRS Approves Rescission of CRAT That Failed 10% Requirement 6. IRS Approves Rescission of CRAT That Failed 10% Requirement

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Validity of Shark-Fin CLATs Remains in Doubt Despite IRS Guidance (18 pp) (relevancy score: 100%)

by Richard L. Fox
from Charitable Planning in a Time of Low Interest Rates (December 8, 2010)

58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 2 Document Outline Validity of Shark-Fin CLATs Remains in Doubt Despite IRS Guidance 7. Validity of Shark-Fin CLATs Remains in Doubt Despite IRS Guidance

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All-Time Low IRS Interest Rates Offer Substantial Estate and Charitable Planning Opportunities (4 pp) (relevancy score: 100%)

by Richard L. Fox
from Charitable Planning in a Time of Low Interest Rates (December 8, 2010)

Nonetheless, as with a GRAT, the to interest rates and optimizes the estate and gift tax "excess income" earned by the CLAT passes to the savings when the IRS interest rates are low, as is the child estate and gift tax free. $1,000,000 lifetime gift tax exemption limitation, The trust invests the funds, presumably earning vehicles that eliminate or minimize gift tax exposure income at a higher rate. gift tax (and no gift tax if sufficient lifetime gift tax exemption Assuming the IDGTs earn ...

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A Guide to the IRS Sample Charitable Lead Trust Forms – Part 1 (12 pp) (relevancy score: 100%)

by Richard L. Fox
from Charitable Planning in a Time of Low Interest Rates (December 8, 2010)

80 81 82 83 84 85 86 87 88 89 90 2 Document Outline A Guide to the IRS Sample Charitable Lead Trust Forms ? Part 1 9. A Guide to the IRS Sample Charitable Lead Trust Forms ? Part 1

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A Guide to the IRS Sample Charitable Lead Trust Forms – Part 2 (18 pp) (relevancy score: 100%)

by Richard L. Fox
from Charitable Planning in a Time of Low Interest Rates (December 8, 2010)

92 93 94 95 96 97 98 99 100 101 102 103 104 105 2 ALI-ABA 09/07/2010 STATE MCLE CONTACTS Alabama Delaware Indiana Minnesota Ms. Angela Parks Ms. Margot Millar Ms. Julie Orzeske Ms. Liz Vanderbeek Director of Regulatory Programs Executive Director Executive Director CLE Administrator Alabama State Bar Commission on CLE of the Supreme Indiana Supreme Court Minnesota Board of CLE 415 Dexter Avenue Court of Delaware Indiana Commission for CLE Suite 950 PO Box 671 Carvel State Office Building 30 ...

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2010 GST Tax Planning: Time is Critical (6 pp) (relevancy score: 100%)

by
from Year-end Estate and Gift Planning in Chaotic Times (December 2, 2010)

2 3 4 5 6 Document Outline 2010 GST Tax Planning: Time is Critical 1. 2010 GST Tax Planning: Time is Critical

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