#estate-planning

Estate Planning

Tax-efficient strategies for transferring wealth and business assets to the next generation

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17 юли 2026 г.

When a Deficit Restoration Obligation Isn't One: What CCA 202628009 Means for Partnership Loss and Liability Allocations

IRS Chief Counsel Advice CCA 202628009 (July 10, 2026) held that a demand-based deficit restoration obligation enforceable only by withholding future distributions is not unconditional, failing both the §1.704-1(b) economic-effect safe harbor and the §1.752-2(b) recourse-liability test — a fact pattern common in family LP boilerplate that can reallocate recourse debt and suspend previously deducted losses.

mike

taxpartnershipstax-compliance

15 юли 2026 г.

Your Credit Union Trust Account Just Got a Simpler (and Possibly Smaller) Insurance Rule

Effective December 1, 2026, the NCUA insures all credit union trust accounts — revocable and irrevocable alike — under one formula, $250,000 per beneficiary capped at $1,250,000 per owner per credit union, matching the FDIC's 2024 bank rule. Trusts naming more than five beneficiaries may lose coverage they hold today, so this guide walks through a five-step balance check to run before the deadline.

mike

bankinginsurancecompliance

11 юли 2026 г.

Executor Accounting: What Fiduciary Duty Requires You to Show Beneficiaries

An executor is a fiduciary, which means beneficiaries have a legal right to a formal accounting of every dollar that moved through an estate — and failing to produce one can trigger removal or personal liability, regardless of whether any money was actually mishandled.

mike

estate-planningfiduciarylegal

10 юли 2026 г.

Digital Estate Planning for Business Owners: What Happens to Your Domains, Crypto, and Cloud Accounts When You're Gone

An estimated 20% of all Bitcoin is permanently inaccessible because owners died without sharing private keys — a practical guide to inventorying domains, crypto wallets, and cloud accounts under RUFADAA before a crisis forces the issue.

mike

estate-planningsuccession-planningdigital-assets

4 юни 2026 г.

Section 1202 QSBS After the One Big Beautiful Bill Act: Tiered Holding Periods, the $15 Million Cap, and Trust Stacking

How the One Big Beautiful Bill Act rewrote Section 1202 QSBS — a tiered 50/75/100% gain exclusion at three, four, and five years; a $15 million per-issuer cap; a $75 million gross asset threshold at issuance; and non-grantor trust stacking that can lift a founder's combined exclusion well past the single-taxpayer limit.

mike

taxtax-planningequity

19 май 2026 г.

Section 685 Qualified Funeral Trusts: Making the QFT Election, Form 1041-QFT, and Reconciling State Pre-Need Rules

How funeral homes, cemeteries, and memorial providers use the IRC Section 685 election on Form 1041-QFT to tax pre-need trust income at per-contract individual brackets — and how to reconcile state pre-need rules, deferred revenue, and restricted trust assets on the operator's books.

mike

form-1041trusttax-compliance

18 май 2026 г.

California Proposition 19 and the End of the Old Parent-Child Property Tax Bargain: A 2026 Guide for Heirs of California Real Estate

How California's Proposition 19 replaced Section 63.1 for parent-child transfers after February 16, 2021 — the family home and farm rules, the one-year occupancy requirement, the BOE-19-P and BOE-266 filings, the $1,044,586 value cap floor, and the step-up-basis trade-off that determines whether to gift during life or transfer at death.

mike

real-estateestate-planningtax

18 май 2026 г.

The $15 Million Estate Tax Exemption Is Now Permanent: How High-Net-Worth Families Should Recalibrate SLATs, GRATs, and Lifetime Gifts in 2026

The One Big Beautiful Bill Act locks the federal estate, gift, and GST exemption at $15 million per individual with no sunset. Here is what changes for SLATs, GRATs, dynasty trusts, GST allocation, and basis planning in 2026 — and what to actually do this year.

mike

estate-planningtax-planningtrust

18 май 2026 г.

Section 1041 and Divorce: A Guide to Property Transfers, Carryover Basis, and QDROs

Section 1041 lets spouses transfer property tax-free during and after divorce, but carryover basis, the six-year window, QDROs, ISO conversions, and post-TCJA alimony rules quietly reshape every settlement. A working guide to what must be fixed before the decree is signed.

mike

divorcetax-planningcapital-gains

18 май 2026 г.

Section 1235 Capital Gains Treatment for Patent Sales: How Inventors Convert Royalty Income Into Long-Term Capital Gain

Section 1235 lets individual inventors and qualifying early investors treat a patent sale as long-term capital gain — even without a one-year holding period — if they transfer all substantial rights. This guide explains who qualifies as a holder, why the rule survived the TCJA carve-out for self-created intangibles, and how to draft the transfer so the IRS sees a sale rather than a royalty license.

mike

tax-planningcapital-gainstax

17 май 2026 г.

Form 3520-A: The March 15 Deadline, Substitute Filings, and the 5% Section 6677 Penalty

Form 3520-A is the annual information return for a foreign trust with a U.S. owner, due March 15. If the foreign trustee does not file, Section 6677 imposes an initial 5% penalty on trust assets plus $10,000 per 30-day continuation period — payable by the U.S. owner. Covers who files, the substitute filing path, the reasonable-cause defense, and how to clean up multi-year non-compliance.

mike

taxinternational-taxtax-compliance

16 май 2026 г.

Crummey Letters and ILITs: How High-Net-Worth Families Keep Life Insurance Out of Their Taxable Estate

A working guide to ILITs and Crummey powers — covering Section 2042 incidents of ownership, the annual gift tax exclusion, the 5-or-5 rule, hanging powers, the Section 2035 three-year lookback, and the administrative discipline that keeps life insurance death benefits estate-tax-free.

mike

estate-planningtax-planninginsurance

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