#estate-planning
Tax-efficient strategies for transferring wealth and business assets to the next generation
Section 7702B sets the federal rules that decide whether a long-term care policy delivers deductible premiums, tax-free benefits, and tax-free 1035 exchanges. This guide breaks down the 2026 age-indexed deduction limits, the $430 per-diem cap, hybrid life-LTC mechanics, and the planning patterns that move trapped cash value into care coverage without recognizing gain.
A practical 2026 guide to Family Limited Partnership valuation discounts — how high-net-worth families combine 10–25% lack-of-control and 20–35% lack-of-marketability discounts to cut estate and gift tax exposure, with worked numerical examples, the IRC Section 2036 traps that have collapsed estates in Tax Court, setup costs, and the bookkeeping required to defend the structure on audit.
Trusts hit the top 37% federal bracket at just $15,200 of taxable income, while a single individual does not until $609,350. This guide walks fiduciaries through Form 1041, distributable net income (DNI), Schedule K-1 allocations, the separate share rule, and the 65-day election used to shift income to beneficiaries at lower rates.
A 2026 fiduciary's guide to Form 1041 — why trust brackets hit 37% at $15,200, how distributable net income routes taxable income to beneficiaries through Schedule K-1, and how the 65-day election cuts the tax bill after year-end.
A 2026 guide to the U.S. generation-skipping transfer (GST) tax — the permanent $15 million lifetime exemption under the One Big Beautiful Bill, who counts as a skip person, the three triggering events, dynasty trust mechanics, and the Forms 709, 706, and 706-GS that grandparent-to-grandchild transfers require.
For 2026 the One Big Beautiful Bill Act sets the GST exemption at $15 million per person ($30 million per couple), with a flat 40 percent rate on transfers to skip persons; this guide covers skip-person rules, direct skips, taxable terminations, automatic versus elective exemption allocation, and how dynasty trusts achieve a zero inclusion ratio.
How the Intentionally Defective Grantor Trust (IDGT) installment sale freezes estate value at today's AFR, why Revenue Ruling 2023-2 ended the basis-step-up shortcut for grantor trust assets, and the formalities that decide audit outcomes.
Section 1259 treats short-against-the-box trades, equity swaps, and tight collars on appreciated stock as constructive sales — taxable today, even with no proceeds. Covers the variable prepaid forward workaround, the 30-day closing exception, and the related-party trap.
Section 645 election lets a revocable trust file as part of its estate on one Form 1041. Learn Form 8855 rules, fiscal year choices, and the irrevocable
A Section 754 election triggers a 743(b) inside-basis step-up when a partner dies, sells, or is bought in — preventing heirs and incoming partners from paying tax twice on the same appreciation. This guide covers 743(b) and 734(b) mechanics, Section 755 allocation across asset classes, the substantial built-in loss rule, Form 15254 revocation, and when the administrative cost outweighs the benefit.
A fiduciary guide to the Section 663(b) 65-day election and the Section 643(g) Form 1041-T allocation, with the March 6 deadline, DNI mechanics, a worked example saving roughly $11,776 in federal tax, and the procedural traps that void the election.
Section 7702A's 7-pay test reclassifies overfunded cash-value life insurance as a modified endowment contract, switching lifetime distributions to LIFO ordering, taxing policy loans as ordinary income, and adding a 10% penalty before age 59½. The classification is permanent and cannot be reversed after the 60-day refund window.
