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Estate Planning

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

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.

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.

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.

Form 706-NA: The $60,000 Trap That Can Turn a Foreign Investor's U.S. Real Estate Into a 40% Estate Tax Bill

Nonresident aliens who own U.S. real estate, U.S. corporate stock, or other situs property get only a $60,000 estate tax exemption — not the $13.99 million citizens enjoy in 2026 — and pay up to 40% on the excess. A working guide to Form 706-NA, FIRPTA withholding, treaty relief via Form 8833, transfer certificates, and the blocker-corporation structures that actually work.