gift tax exclusion

• Portability of unused estate and gift tax exclusion between spouses.

One of the essential elements in the equation for the computation of both the federal gift and estate tax is the reduction of the tax due by the amoun...

• The Tax Adviser
• Vol. 42 Nbr. 5, May 2011

• Handler Thayer, Llp Tax Alert - Spring 2011

CHICAGO, April 16, 2011 /PRNewswire/ -- Income tax, gift tax and estate tax planning have taken on a new level of importance due to the effects of the Tax Reform Act of 2010 ("the Act"). Because the Act sunsets on December 31, 2012, there is increased urgency to act sooner rather than later. Further, current planning should be viewed as opportunistic and short-term rather than long-term in nature. In fact, the 2012 budget proposals recently announced by the Obama Administration raise tax rates and change the lifetime gift tax exclusion amount as of January 1, 2012. Consequently, there is no assurance that the current, highly-favorable income tax and estate tax laws will be available in 2012, much less in 2013. (Logo: http://photos.prnewswire.com/prnh/20100429/CG95838LOGO)

• U.S. Newswire
• April 16, 2011

• Contingent beneficiaries and the annual gift tax exclusion.

The IRS and the Tax Court have addressed the use of trusts and the annual gift tax exclusion as vehicles for wealth transfer, and the expansion of the exclusion to cover interests placed in trust for contingent beneficiaries may expand estate planning options. The Tax Court disregarded the IRS's distinction between contingent and present beneficiaries and found in Estate of Cristofani that the beneficiaries' legal power to withdraw funds from the trust qualified contributions to the trust for the annual gift tax exclusion. Tax planners should follow the Tax Court's ruling and use the annual exclusion for contingent beneficiaries.

• The Tax Adviser
• Vol. 25 Nbr. 4, April 1994

• More Than One Way to Minimize Uncle Sam's Bite

Let's say someone owns a business that has a fair market value of $3 million on Dec. 31, 2007," says [Rita Danylchuk]. "Let's also say the business grows and is worth $5 million upon her death two years later. If she leaves it to her son but does not create an IDGT, the entire $5 million value of the business, less the grantor's $2 million estate tax exemption, would generally be subject to federal estate tax. If she leaves it to her son but does not create an IDGT, the entire $5 million value of the business, less the grantor's $2 million estate tax exemption, would generally be subject to federal estate tax. [...] at a one-third discount [to the fair market value of the ownership interest], a husband and wife with two children might be able to give away about $72,000 of ownership s...

...The simplest way would be to annually gift-or transfer to your designated successor-a predete... or reducing their ultimate estate tax exclusion.". One reason for the discount is that a minority ...

• NJBIZ
• August 19, 2009

• Effectively using the annual gift tax exclusion.

Estate taxes can be minimized by planning with the annual gift tax exclusion. Through the use of numerous examples, this two-part article demonstrates...

• The Tax Adviser
• Vol. 32 Nbr. 6, June 2001

• A comparative proposal to reform the United States gift tax annual exclusion.

TABLE OF CONTENTS I. INTRODUCTION A. The U.S. Gift Tax B. The Role of the Annual Exclusion in Estate and Gift Tax C. Annual Exclusion Abuse ...

• Vanderbilt Journal of Transnational Law
• Vol. 30 Nbr. 5, November 1997

• Effectively using the annual gift tax exclusion.

Part I of this two-part article examined the significant long-term benefits of the annual exclusion. Part II focuses on other issues and available pla...

• The Tax Adviser
• Vol. 32 Nbr. 7, July 2001

• Gift tax exclusion becomes tool in year-end planning.

Guest Column

• San Fernando Valley Business Journal
• November 21, 2005

• Will a Crummey beneficial interest qualify for an annual gift tax exclusion?

The IRS continues to question the substance of Crummey trust arrangements being used to take advantage of annual gift tax exclusions under IRC section 2503(b) despite recent decisions unfavorable to the IRS. Unlike other trust interests, a Crummey trust interest qualifies for the gift tax exclusion because the limited withdrawal right offered the beneficiary results in the interest being considered a present interest. The IRS has argued for proof of donative intent, but the Tax Court ruled in Estate of Cristofani that contingent remainder interests are sufficient under Crummey.

• The Tax Adviser
• Vol. 28 Nbr. 6, June 1997

• No annual gift tax exclusion for gift of LLC membership units.

Limited liability company

• Journal of Accountancy
• Vol. 197 Nbr. 1, January 2004