#estate-planning
Estate Planning
Tax-efficient strategies for transferring wealth and business assets to the next generation
Canada's New Bare Trust Reporting Rules Under Bill C-15: Who Actually Has to File for the 2026 Tax Year
Bill C-15 makes bare trust reporting mandatory in Canada for tax years ending on or after December 31, 2026, with T3 and Schedule 15 filings due March 31, 2027. Covers which small-business arrangements count as bare trusts, the narrow $50,000/three-month exemption, and penalties up to 5% of trust property value.
Spousal Lifetime Access Trusts (SLATs): How Business Owners Move Future Growth Out of Their Estate
A Spousal Lifetime Access Trust (SLAT) lets a business owner move an appreciating asset — and all its future growth — out of the taxable estate while the beneficiary spouse retains access to distributions. With the 2026 lifetime exemption set at $15 million per individual, this guide covers the mechanics, valuation discounts, the reciprocal trust doctrine, and the divorce and death risks to plan around.
The $15 Million Estate Tax Exemption: What OBBBA Means for Business Succession Planning
The One Big Beautiful Bill Act permanently raised the federal estate and gift tax exemption to $15 million per person ($30 million per couple) starting in 2026, eliminating the scheduled TCJA sunset to roughly $7 million. Here's what changed, which existing plans are now outdated, and the succession moves business owners should make — from portability filings to buy-sell agreement reviews and state estate tax exposure.
Split-Dollar Life Insurance, Explained: How Business Owners and Key Employees Share the Cost of a Policy
Split-dollar life insurance is an agreement — not a policy type — for an employer and a key employee to divide the premiums, cash value, and death benefit of one permanent policy. This guide compares the two structures (collateral assignment vs. endorsement), explains how the IRS taxes each under the economic benefit and loan regimes, why premiums are never deductible, and how to book the arrangement correctly from day one.
Community Property Trusts: How Business Owners in Any State Can Get a Full Basis Step-Up
Alaska, Tennessee, Kentucky, Florida, and South Dakota let married couples in any state opt into community property treatment through a trust, so the entire asset — not just half — gets an IRC Section 1014(b)(6) basis step-up at the first spouse's death. What business owners should know about Section 754 elections, the one-year gift trap under Section 1014(e), and the unresolved IRS guidance.
Lewis v. Commissioner: What a $53 Million QTIP Trust Dispute Teaches About Defensible Valuations
In Lewis v. Commissioner, the Tax Court valued remainder interests surrendered when a $117.6 million QTIP trust terminated early — the IRS said $53.4 million per child, the taxpayers said $156,000, and the court's four rulings on state law, powers of appointment, net-gift math, and actuarial tables landed at $35.1 million.
Trump Account Gift Tax Rules: The IRS Safe Harbor That Spares Most Families From Form 709
IRS Revenue Procedure 2026-25 (June 29, 2026) creates a gift tax safe harbor for Trump Account contributions: individual donors whose total gifts to a child stay under the $19,000 annual exclusion owe no Form 709 filing, resolving the future-interest question raised by the accounts' lock-up until age 18.
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.
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.
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.
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.
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.