Estate and Gift Taxation Current Developments: Connelly v. IRS, Rev Ruling 2023-2's Impact on Grantor Trusts
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This webinar will address the latest developments in gift and estate taxation, including the SCOTUS decision in Connelly v. United States, Revenue Ruling 2023-2's impact on grantor trusts and basis step-up, the continuing impact of the sunset of the lofty estate tax exclusion, and other recent legislation. Our panel of generational wealth experts will explain which estates are impacted by recent changes and offer planning tips to minimize related transfer taxes.
Outline
- Current developments in estate and gift taxation: introduction
- Revenue Ruling 2023-2
- Revenue Procedure 2022-32: Extension of Time to File Portability Election
- Connelly v. United States
- CCA 202352018 – Grantor trust reimbursements
- Cecil v. Commissioner and valuation discounts
- Proposed regulations
- Exceptions to anti-clawback rules
- Administrative expenses, claims against an estate, interest expense
- Other developments
Benefits
The panel will explore these and other critical issues:
- Which estates are eligible for the extensions of time to elect portability under Rev Proc 2022-32?
- How Connelly v. United States impacts estate planning for business owners
- What transfers are considered de minimis and not subject to the exceptions to the anti-clawback regulations?
- How Revenue Ruling 2023-2 impacts grantor trusts
Faculty
Justin D. Alt
Counsel
Willkie Farr & Gallagher
Mr. Alt is counsel in the Private Clients Group, based in Los Angeles. A trusts and estates attorney with a strong... | Read More
Mr. Alt is counsel in the Private Clients Group, based in Los Angeles. A trusts and estates attorney with a strong background in tax law, he routinely represents estates and donors before the Internal Revenue Service (IRS) in highly complex transfer tax controversies, drafts and prepares a wide range of estate planning documents, and advises on general business and tax planning strategies. Mr. Alt previously worked as an estate tax attorney at the IRS, where he performed reviews of estate and gift tax returns, developed complex cases for litigation, and negotiated resolutions and settlements in estate and gift tax controversies.
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S. Gray Edmondson
Partner
Edmondson Sage Allen
Mr. Edmondson practices in partnership, corporate, and individual tax planning; business transactions including mergers... | Read More
Mr. Edmondson practices in partnership, corporate, and individual tax planning; business transactions including mergers and acquisitions; business planning; tax controversy; estate and wealth transfer planning; probate; estate and trust litigation; asset protection; and charitable planning. He has conducted, authored, and directed numerous seminars for professional, academic, and civic groups on taxation, business, asset protection and estate planning. Mr. Edmondson works closely with clients to develop and implement such strategies.
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