Increased Estate/Gift Tax Exemptions Under TCJA: No-Clawback, but Use it or Lose It
February 11, 2019
by Christopher T. Rogers
The Tax Cuts and Jobs Act (“TCJA”) passed in December, 2017, doubled the estate and gift tax basic exclusion amount from $5.0 million to $10.0, coupled with a cost of living adjustment. For 2019, the basic exclusion amount is $11.4 million. Unless extended, the increased basic exclusion amount…
New PLR Addresses Special Trustee's Power to Limit or Eliminate Testamentary General Power of Appointment
November 6, 2018
by Ashley L. Gill
IRS Rules Appointment of Special Trustee and Special Trustee’s Subsequent Exercise of Power to Limit or Eliminate Trust Beneficiary’s Testamentary General Power of Appointment Will Not Constitute Exercise or Release for Purposes § 2514 or § 2041 of the Code The IRS recently issued a private letter…
Why 2019 Will Be the Year of Opportunity (Zones)
November 6, 2018
by Craig R. Cockrell
One of the more significant additions to the Tax Code under the 2017 Tax Cuts and Jobs Act was the creation of an incentive program for investment in certain low income communities called “Opportunity Zones.” The program is designed to spur economic investment in distressed areas by allowing…
Repeal of the Personal Property Like-kind Exchange (… or, the Swap of §1031 for Increased Bonus Depreciation and Expensing)
One of the lessor discussed items in the recently enacted Tax Cuts and Jobs Act (“TCJA”) has been the change to Section 1031, limiting the like-kind exchange provisions to exchanges of real property only. Section 1031 of the Internal Revenue Code provides an exception to the general gain…
Tax Practitioners May Use Return Information to Market to their Return Preparation Clients, But Some Use and Disclosures Require Written Consent Beforehand
Accounting firms have specific rights and duties that come into play when they market to their clients using data gleaned from the return preparation process. The general rule is that returns and return information cannot be disclosed without consent. For example, on the government side Section…