Estate and Gift Taxation Current Developments: Connelly v. IRS, Rev Ruling 2023-2's Impact on Grantor Trusts

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Course Details

Course Information

smart_display Format
On-Demand
signal_cellular_alt Difficulty Level
Intermediate
work Practice Area
Tax Preparer

Date & Time

event Date
Friday, June 28, 2024
schedule Time
1:00 p.m. ET./10:00 a.m. PT
timer Program Length
110 minutes

Credit Information

BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$197.00

This webinar will address the latest developments in gift and estate taxation, including the SCOTUS decision in Connelly v. United States, Revenue Ruling 2023-2's impact on grantor trusts and basis step-up, the continuing impact of the sunset of the lofty estate tax exclusion, and other recent legislation. Our panel of generational wealth experts will explain which estates are impacted by recent changes and offer planning tips to minimize related transfer taxes.

Faculty

S. Gray Edmondson

Partner

Edmondson Sage Allen, PLLC

Mr. Edmondson practices in partnership, corporate, and individual tax planning; business transactions including mergers and acquisitions; business planning; tax controversy; estate and wealth transfer planning; probate; estate and trust litigation; asset protection; and charitable planning. He has conducted, authored, and directed numerous seminars for professional, academic, and civic groups on taxation, business, asset protection and estate planning. Mr. Edmondson works closely with clients to develop and implement such strategies.

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Justin D. Alt

Counsel

Willkie Farr & Gallagher, LLP

Mr. Alt is counsel in the Private Clients Group, based in Los Angeles. A trusts and estates attorney with a strong background in tax law, he routinely represents estates and donors before the Internal Revenue Service (IRS) in highly complex transfer tax controversies, drafts and prepares a wide range of estate planning documents, and advises on general business and tax planning strategies. Mr. Alt previously worked as an estate tax attorney at the IRS, where he performed reviews of estate and gift tax returns, developed complex cases for litigation, and negotiated resolutions and settlements in estate and gift tax controversies.

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Description

June 2024, the Supreme Court issued a landmark decision in Connelly v. United States siding with the Internal Revenue Service. It determined that life insurance proceeds should be included a business valuation, and hence an estate, when a company has a buy sell agreement in place that is triggered by the death of a shareholder. The decision has major implications for estate planning for business owners.

The April 2023 IRS Bulletin summarized Revenue Ruling 2023-2 by stating that the Ruling "confirms that the basis adjustment under section 1014 generally does not apply to the assets of an irrevocable grantor trust not included in the deceased grantor's gross estate for Federal estate tax purposes," thus challenging the use of IDGTs (intentionally defective grantor trusts), which have been a historically valuable estate planning tool. Continuing to develop are planning opportunities surrounding the impending reversion of the estate tax exclusion to 2017 amounts.

Listen as our panel of transfer tax experts reviews the latest developments in estate and gift tax for trust and estate professionals.

Outline

Current developments in estate and gift taxation: introduction
Revenue Ruling 2023-2
Revenue Procedure 2022-32: Extension of Time to File Portability Election
Connelly v. United States
CCA 202352018 – Grantor trust reimbursements
Cecil v. Commissioner and valuation discounts
Proposed regulations
- Exceptions to anti-clawback rules
- Administrative expenses, claims against an estate, interest expense
Other developments

Benefits

The panel will explore these and other critical issues:

Which estates are eligible for the extensions of time to elect portability under Rev Proc 2022-32?
How Connelly v. United States impacts estate planning for business owners
What transfers are considered de minimis and not subject to the exceptions to the anti-clawback regulations?
How Revenue Ruling 2023-2 impacts grantor trusts

NASBA Details

Learning Objectives

After completing this course, you will be able to:

Decide how Revenue Ruling 2023-2 impacts grantor trusts
Determine how Cecil v. Commissioner impacts valuation discounts
Ascertain how the SCOTUS decision impacts estate planning for business owners
Identify which estates are eligible for the extension of time to elect portability under 2022-32

Field of Study: Taxes
Level of Knowledge: Intermediate
Advance Preparation: None
Teaching Method: Seminar/Lecture
Delivery Method: Group-Internet (via computer)
Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
Prerequisite: Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of estate, gift and trust taxation including various trusts types, the unified credit, and portability.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.