American Tax Payer Relief Act 2012

The Estate Planner’s Guide to the “Deal”

The business attorney’s focus when advising a client selling a business is necessarily the transaction itself. Primary considerations typically include maximizing the purchase price, reducing the income and other (e.g., real estate excise) taxes resulting from the transaction, and minimizing post-transfer contingencies placed upon the seller’s receipt of the sale proceeds (e.g., earn-out provisions). Although all of these factors are … Continue reading »

States

Changing Your Residency to Avoid Washington Estate Tax

For Washington residents facing the possibility of a sizable estate tax bill, establishing residency in a different state may be worth considering, particularly for those who already have a second residence in another state. Establishing residency in another state may provide a tax advantage for some, but for others, the burdens of moving to a new home state ultimately override … Continue reading »

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Tax Court Rules for MPBA Clients in Rejecting Aggressive IRS Estate Tax Claim

In Estate of Purdue, T.C. Memo. 2015-249, the United States Tax Court denied an IRS attempt to disregard lifetime estate planning implemented by Barbara and Robert Purdue (the “Purdues”). MPBA attorneys, primarily Alan L. Montgomery and George W. Akers, advised Mr. and Mrs. Purdue with respect to the lifetime planning, and also represented Mrs. Purdue’s estate (the “Estate”) at the Tax Court. The Estate … Continue reading »

estatetaxplanning

Proposed IRS Regulations May Limit Tax-Favorable Estate Planning Strategies

The IRS recently announced new proposed regulations which may eliminate or significantly reduce valuation discounts on transfers of family entity interests (e.g., LLCs, limited partnerships, and corporations). Although there are several uncertainties regarding the scope of these new rules, the proposed regulations, if enacted, could result in substantial increases in estate, gift, and generation-skipping transfer taxes for many taxpayers. Continue reading »

Estate Planning Update One Page

2014 Estate Planning and Tax Update

How have federal income tax laws changed recently? While the 2012 Tax Act did not change income tax rates for most taxpayers, those individuals with incomes over $400,000 and married couples filing jointly with incomes over $450,000 are now subject to a highest marginal rate of 39.6%, up from 35%. A 20% rate now applies to long-term capital gains and … Continue reading »