Upcoming Events

Some pundits are referring to CCA 202352018 as the most important IRS ruling in a decade, and the reason is crystal clear: if adding a discretionary power allowing the trustee to reimburse the grantor for income taxes now results in a taxable gift, clients who have sold/gifted appreciating assets to grantor trusts could be in significant financial jeopardy because as the value of those assets appreciates, they may not have the cash to pay their income tax bills. At a minimum, this new IRS guidance will have far-reaching implications that will force estate planners and their clients to rethink conventional wisdom regarding the gift tax consequences of amending, modifying and decanting irrevocable trusts.

In their exclusive LISI Webinar, Jonathan Blattmachr, Bob Keebler and Martin Shenkman will carefully review the planning issues raised by this landmark guidance. Here are just a few of the issues they will cover:

·Will decanting assets from an existing irrevocable trust to a new trust in a manner that reduces a beneficiary’s interest in the original trust now result in a taxable gift to the other beneficiaries?

·Can a beneficiary’s continuing interest in a modified trust constitute a non-qualified retained interest for purposes of Section 2702 of the Code? Further, would that beneficiary be treated as having made a taxable gift of his or her entire interest in the trust?

·Could a beneficiary’s failure to object to a proposed trust alteration be treated as equivalent to the beneficiary’s consent to the alteration for purposes of determining if a taxable gift has occurred?

What can be done in 2024 to prepare clients for the best decisions in actions both now and in 2025.

In this fast-paced webinar Bob Keebler will present a summary of California’s new fiduciary income tax law requiring incomplete trusts to be taxed in California as a California grantor trust.

This is must-have information for all California, Alaska, Delaware, Nevada, South Dakota and Wyoming trust officers, CPAs and trust and estate lawyers.

Bob will address precisely what the Bill does and solutions, including:

• Overview of prior California law and Federal law.
• Overview of the new statute.
• The election to be treated as a California “nongrantor trust.”
• No free lunch on earlier “throwback years.”
• The use of completed gift trusts to avoid the reach of the California law.
• The use of charitable remainder trusts to defer Federal and California Tax.
• Transferring property from existing INGs to completed gift trusts.
• Selling property from INGs to completed gift trusts via IRC § 453 installment sales.
• Using life insurance and other tax shelter strategies.
• Other ideas to mitigate California’s attempt to checkmate the ING strategy.

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In this fast-paced webinar Bob Keebler will present a summary of California’s new fiduciary income tax law requiring incomplete trusts to be taxed in California as a California grantor trust.

This is must-have information for all California, Alaska, Delaware, Nevada, South Dakota and Wyoming trust officers, CPAs and trust and estate lawyers.

Bob will address precisely what the Bill does and solutions, including:

• Overview of prior California law and Federal law.
• Overview of the new statute.
• The election to be treated as a California “nongrantor trust.”
• No free lunch on earlier “throwback years.”
• The use of completed gift trusts to avoid the reach of the California law.
• The use of charitable remainder trusts to defer Federal and California Tax.
• Transferring property from existing INGs to completed gift trusts.
• Selling property from INGs to completed gift trusts via IRC § 453 installment sales.
• Using life insurance and other tax shelter strategies.
• Other ideas to mitigate California’s attempt to checkmate the ING strategy.

Roth conversions have always had the potential to unlock hidden value. However, 2024 may be an especially effective year to consider a conversion as many marginal tax rate increases seem to be clearly on the horizon along with significant changes to conversion and accumulation rules. Should there be substantial market volatility the timing may be near perfect.

Moreover, SECURE 2.0 expands the impact of Roth conversions beyond a quantitative arbitrage game to a strategic estate planning issue. Therefore, quantitative driven strategies can mitigate the impact of lost deferral and Roth conversions will be the primary tool for most families.

Specifically, this webinar will cover the following topics:

• Low value Roth conversions
• Repaying coronavirus-related distributions to a Roth Account
• Critical Roth conversion concepts after SECURE
• 10+ Reasons to convert to a Roth IRA
• Taxation of Roth IRA conversions and distributions
• Easy to read conversion tables by common scenarios
• Mathematics of Roth IRA conversions
• Timing of Roth IRA conversions to gain tax rate arbitrage
• Estate tax considerations and why a Roth conversion is much better when an estate tax exists
• Hedging Roth conversions with life insurance
• Using insurance to preserve post-death “stretch-out”

In this class Bob Keebler will review the following:

• The use of charitable remainder trusts to defer and eliminate capital gains
• The use of 453 installment sales to reduce capital gains and how to elect out of installment sale treatment to accelerate gains into 2025
• The Math of recognizing capital gains in 2024
• Grantor charitable lead trusts to decrease capital gains
• Direct charitable gifts to reduce capital gains
• Opportunity zones to more effectively manage capital gains
• Integrating loss harvesting in an overall capital gains strategy
• Using 1031 exchanges to ease capital gains
• The use of collars, variable forward sales and options to better manage capital gains
• IRC 1259 “choking” collar to trigger capital gains in 2024 or defer to a future date
• “Short against the box” strategies to choose between recognizing gains in 2024 or 2025

In this class Bob Keebler will review the following:

• The use of charitable remainder trusts to defer and eliminate capital gains
• The use of 453 installment sales to reduce capital gains and how to elect out of installment sale treatment to accelerate gains into 2025
• The Math of recognizing capital gains in 2024
• Grantor charitable lead trusts to decrease capital gains
• Direct charitable gifts to reduce capital gains
• Opportunity zones to more effectively manage capital gains
• Integrating loss harvesting in an overall capital gains strategy
• Using 1031 exchanges to ease capital gains
• The use of collars, variable forward sales and options to better manage capital gains
• IRC 1259 “choking” collar to trigger capital gains in 2024 or defer to a future date
• “Short against the box” strategies to choose between recognizing gains in 2024 or 2025

There have been changes in estate, tax, income, and retirement planning laws coming for a while now and it is more imperative than ever for estate planners to stay on top of these changes. Includes: Monthly bulletin sent via e-mail (approximately the third week of the month). Subscribe for $49 per month.

Most estate planning professionals are already very well aware that the SECURE Act brought with it some of the biggest changes to IRA planning for clients than we have seen during our lifetime. That’s why it’s so important as estate planners that we have what we need to understand the SECURE Act and what you need to know to properly advise your clients.

This is why we, as we have in the past, have teamed up with nationally renowned CPA and IRA expert, Robert S. Keebler, to break it down for you so that you don’t have to do it yourself. Subscribe to the Printable EBook. (Includes: Downloadable, printable PDF e-Book. Pages 108.)