Effective July 8, 2022, the IRS issued Revenue Procedure 2022-32 to supersede Revenue Procedure 2017-34 and now allow for a late estate tax exemption portability election to be made up to five (5) years from a deceased spouse’s death. Previously, this window was only two (2) years from the deceased spouse’s death. Revenue Procedure 2022-32
Estate Tax
2022 Changes to Estate and Gift Tax Exclusions
By David J. Choyne & Gary A. Phillips on
The IRS released Revenue Procedure 2021-45 which announces the increase in 2022 of the estate, gift and generation-skipping transfer tax applicable exclusion amounts from $11.7 million to $12.06 million. The applicable exclusion amounts currently remain scheduled to expire on December 31, 2025, which would result in a reduction in the exclusion amounts to $5 million…
Gift Planning in 2021
By Steven M. Saraisky on
Trust and estate planners are still catching their breath from the 2020 year-end and dealing with the wave of gifting transactions that many clients completed. It seems the ink is not dry on those December transactions and we have to pivot and focus on getting gift tax returns completed.
The 2020 year-end was extremely busy…
2020 Estate and Gift Tax Update
By Gary A. Phillips & Tishya M. Signorelli on
Posted in Estate Tax, Federal Gift, Estate and GST Tax
On November 6, the IRS announced the official estate and gift exclusion amounts for 2020 in Revenue Procedure 2019-44.
For an estate of any decedent dying during calendar year 2020, the applicable exclusion is increased from $11.4 million to $11.58 million. This change increases not only the applicable exclusion amount available at death, but also…
Court Finds that Penalty for Late Filing of Estate Tax Return Was Arbitrary and Capricious
By Steven M. Saraisky on
Posted in Estate Tax
Seasoned trusts and estates practitioners know certain truths, such as:
- Stuff happens.
- Some estate tax disputes should not be litigated, but they are anyway.
- Sometimes justice is done.
The recent case of Estate of Skeba (Civil Action No 17-cv-10231, D NJ Oct 3, 2019)) in the District Court of New Jersey reflects all of the…