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Transfer tax planning focuses on gift, estate, and generation-skipping transfer (“GST”) taxes, which are collectively referred to as “transfer taxes.” The base transfer tax exemption amount is $10,000,000 ($12,920,000 million for 2023, as indexed for inflation). Under current law, the base transfer tax exemption amount is set to reduce to…
Category: Tax Planning
On April 28th, Andrew R. Comiter and Adam J. Smith presented on “Key Considerations with Rollover Equity Transactions” at the Taxation of Business Deals and M&A Transactions conference hosted by the The Florida Bar’s Tax Section.
A common question that arises when preparing federal gift tax returns is whether a gift in trust qualifies not only for the gift tax annual exclusion but also for the lesser know (and lesser understood) generation-skipping transfer (“GST”) tax annual exclusion. This article will clarify when gifts in trust…
The IRS issued Rev. Proc. 2022-19, which provides simplified procedures for S corporations and their shareholders to resolve six frequently-encountered issues. For these issues, Rev. Proc. 2022-19 allows S corporations and their shareholders to obtain relief without requesting a private letter ruling (PLR). The IRS identified these issues as not…
On August 24, 2022, the Internal Revenue Service (“IRS”) released Notice 2022-36, which provides relief for eligible taxpayers from failure to file penalties for specified tax returns for the 2019 and 2020 tax years that are filed on or before September 30, 2022. The Department of the Treasury and the…
