Income Taxation of IDGT Sales and Promissory Notes During Life and After Death - A Special Re-Broadcast
One of the most difficult areas of estate planning is the intersection of income tax and estate tax. While many practitioners recognize that the IDGT sale is the cornerstone of planning for larger estates the income tax implications are not as clear as we would like them to be. This becomes very complex because we need to define the taxation during the grantor’s life, at the grantor’s death and after the grantor dies.
In their exclusive LISI Webinar Jonathan Blattmachr and Bob Keebler will review the income tax aspects from three vantage points: during life, at the moment of death, and subsequent to a person’s death. In particular, they will review the following topics:
- Basis of gifted property
- Basis of property in death
- Special rules for IRD
- Understanding the impact of § 691(a) of the Code
- Understanding how §§ 1014 and 1015 work
- Examining the taxation of IDGT sales during life
- Examining the taxation of IDGT sales during life and examining the transactions subsequent to death
- Reviewing Madorin vs. Commissioner and Crane vs. Commissioner, two seminal cases in the world of IDGTs
- Planning for the death of the grantor with ordinary installment notes and with SCINs
- What happens at death when outside debt is greater than the taxpayer’s basis
- Understanding alternative theories espoused by the leading experts, including asymmetrical tax treatment of a basis increase and no gain
- Understanding note basis at death and after death
- Understanding CCA 200923024 and no recognition at death
- Understanding PLR 201245006 which provided for asymmetrical tax treatment
- IRS guidance project outstanding
There will be no CE for this webinar
For those who have a conflict with the date/time, The session will be recorded. Simply register and you will have unlimited access to the recording.
Although they are scheduled for a particular time and date - once purchased - they can be viewed at ANY TIME!.
If you are not a LISI member please use the Buy Now Button below to pay the non-member price of $149.
After you pay you will be sent a link with the registration information. Your webinar registration is designed for one individual user and groups up to 5 individuals. Sharing beyond this is not permitted. If you are interested in group access to our webinar content, please send an email to firstname.lastname@example.org
If you have any questions, please contact email@example.com
NOTE: To pay using a credit card, use the botton labeled
"Pay with Debit or Credit Card" after clicking the Buy Now button below.
If you are a LISI member, please login below to receive the member price of $129 for this webinar.