#estate-planning
Tax-efficient strategies for transferring wealth and business assets to the next generation
A practical 2026 guide to the Charitable Lead Trust: how a zeroed-out CLAT uses the 4.6% Section 7520 rate to fund charity, transfer appreciating assets to heirs, and minimize gift and estate tax — with CLAT vs CLUT and grantor vs non-grantor tradeoffs.
Informal family or employer loans below the AFR trigger IRC Section 7872 imputed interest, treated as gifts, wages, or dividends.
Three valuation approaches — asset, income, and market — can produce 50% differences in indicated value for the same closely-held business. This guide explains when each fits, how DLOM and DLOC discounts apply, and what records owners need before a sale, partner buyout, or estate transfer.
Filing IRS Form 706 to elect portability lets a surviving spouse inherit up to $15 million of unused federal estate tax exemption (the DSUE), shielding combined estates of up to $30 million from the 40% federal estate tax in 2026. Miss the nine-month deadline and Rev. Proc. 2022-32 still allows a late election within five years of death.
How executors of closely-held business estates use IRC Section 6166 to defer federal estate tax across 14 years at a 2% rate, with the 2026 inflation-adjusted $1.94M base, the 35% eligibility test, election mechanics, and the acceleration events that kill the deferral.
A Section 754 election lets a partnership adjust the inside basis of its assets when an interest transfers or property is distributed, preventing incoming partners and heirs from being taxed on appreciation that economically belonged to the seller. The election is permanent, covers both 743(b) and 734(b) adjustments, and matters most for real estate, family, and professional service partnerships.
A practitioner's guide to the tax mechanics of divorce — how a QDRO splits a 401(k) penalty-free, why alimony in agreements executed after 2018 is no longer deductible, how Section 1041 carryover basis can turn a 50/50 settlement into an unequal one, and how the Section 121 home-sale exclusion survives when one spouse moves out.
US OBBBA's 0.5% AGI floor and 35% cap hit in 2026 — how donor-advised fund bunching still clears the federal charitable hurdle.
Section 1042 of the IRC lets a C-corporation owner selling shares to an ESOP defer federal capital gains tax indefinitely — and potentially eliminate it through step-up at death. This guide covers the five qualifying conditions, what counts as Qualified Replacement Property, the floating-rate-note diversification strategy, and the trade-offs founders should weigh against a strategic sale.
A see-through trust named on an IRA beneficiary form must navigate the SECURE Act 10-year rule. Conduit trusts pass every distribution through to the beneficiary by year ten, while accumulation trusts retain assets but face compressed trust brackets that reach the 37 percent federal rate at just $16,000 of retained income in 2026.
How a Charitable Remainder Trust lets you sell appreciated assets without capital gains tax, take an immediate income tax deduction, collect lifetime income, and pass the remainder to charity—plus the math comparing CRUT, CRAT, NIMCRUT, and Flip CRUT structures under the May 2026 5.0% Section 7520 rate.
How founders use zeroed-out GRATs to transfer pre-IPO stock appreciation to heirs tax-free, leveraging the IRS Section 7520 hurdle rate while preserving the lifetime estate exemption.
