Generation-Skipping Transfer Tax

Probably, a majority of lawyers and laypersons perceive that gifts and bequests made outright are simpler and less expensive to implement and provide the beneficiary with more benefits than outright dispositions. Of course, everyone…

The Economic Growth and Tax Relief Reconciliation Act of 2001 (the “Act” or the “2001 Act") temporarily increases the estate and generation-skipping transfer tax exemptions, decreases the gift, estate and generation-skipping transfer tax…

Although qualified personal residence trusts or QPRTs are the most common way for an older family member to transfer one or two homes to younger family members, a Split Purchase Trust may be more where a new home is being acquired—the Split…

Unless falling under an exception, exclusion or special rule, a generation-skipping transfer tax is imposed by IRC §2601 whenever property is transferred through or around one younger generation (such as the generation of the transferor's…

Powers to withdraw property from a trust which ultimately lapse, sometimes generically referred to as "Crummey powers," are a mainstay in estate planning. Their use can have far-reaching property as well as estate, gift and…

Regardless of the motive for making a charitable contribution or bequest, an individual should be aware of the tax effects of the transfer. Failure carefully to consider those effects may not only result in the loss of an income tax…

As the Federal and state governments impose much more onerous estate and inheritance tax laws, such as Chapter 14 of the Internal Revenue Code, it becomes more difficult, expensive and complex for property owners to arrange for the transfer…

As a result of the Tax Reform Act of 1976, the federal estate and gift tax systems were "unified." This unification produced three common features for the estate and gift tax system. First, the rates of taxation for lifetime gifts and…

Before the enactment of I.R.C. §2036(c) by the Rev­enue Act of 1987, transactions were often undertaken in order to stabilize or "freeze" the value of certain assets, for wealth transfer tax purposes, in the hands of older family members,…

Demographers contend that more than one-half of all marriages in America will end by divorce rather than by death. As a consequence, practitioners often are required to undertake estate planning for a property owner who is in a second or…