The April 26, 2022 new clawback proposed regulations provide that a tax payer who dies after 2025may not have a full 12,060,000 exemption for gifts or other transfers that occurred in 2026.It is therefore extremely important that planners understand when the clawback may deprive clients ofone half or more of the estate and gift tax exemption that is now available.
It is also important to note that certain techniques that are quashed by the clawback proposedregulations will never the less be effective and strongly recommended to preserve generationsskipping tax exemption and portability allowances.
The presentation will cover the 18 month rule, the 5% test, common law grits, the three year ruleunder IRC §2035(a), and other important sub topics.
Essential Planning Now for the Clawback Alan Gassman; Brandon Ketron and Martin Shenkman
1 Wills,Trusts, & Estates
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