![]() |
![]() |
Income Taxation of IDGT Sales and Promissory Notes During Life and After Death
Watch Now! |
---|
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*. *plus applicable sales tax (if any)
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 lisiwebinars@gmail.com
If you have any questions, please contact webinaradmin@leimbergservices.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. *plus applicable sales tax (if any)

Bob Keebler
March 3, 2021 3:00 PM ET - 4:30 PM ET ET
THE TAX ASPECTS OF DECANTING AND REFORMING TRUSTS
More Info
![]() |
![]() |
Bob Keebler and Christopher Hoyt
March 3, 2021 1:00 PM ET - 2:30 PM ET
The SECURE ACT and the Charitable Remainder Trust - A Deep Dive - A Special Re-Broadcast
More Info

Bob Keebler
March 4, 2021 11:00 AM ET - 12:30 PM ET
The Nitty-Gritty Details of Income Tax Basis - A Special Re-Broadcast
More Info

Paul Hood
March 04, 2021 1:00PM ET - 2:30PM ET
Part 3 of Paul Hood's Six-Part Series on the Federal Transfer Tax System: Estate Tax Deductions
More Info

Eli Akhavan
March 05, 2021 1:00PM ET - 2:30PM ET
Structuring Foreign Ownership of US Residential Real Estate - Pitfalls and Solutions
More Info
![]() |
![]() |
Michael Geeraerts Jim Magner
March 05, 2021 11:00AM ET - 12:30PM ET
Alternative Life Insurance Ownership Structures if Congress Takes a Swing at ILITs Using New Code Section 2901
More Info

Bob Keebler
March 9, 2021 3:00 PM ET - 4:30 PM ET ET
THE TAX ASPECTS OF DECANTING AND REFORMING TRUSTS
More Info
![]() |
![]() |
Alan Gassman and Brandon Ketron
March 10, 2021 1:00PM ET - 2:30PM ET ET
PPP and Employee Retention Credit (ERC) Update - What's New and What's Still to Come!
More Info

Linas Sudzius
March 11, 2021 3:00PM ET - 4:30PM ET ET
How to Handle an Unexpected Form 1099-R Received from a Life Insurance Company/Financial Institution: Reconciling with all the Tax Partners
More Info

Paul Hood
March 11, 2021 1:00PM ET - 2:30PM ET ET
Part 4 of Paul Hood's Six-Part Series on the Federal Transfer Tax System: Estate Tax Credits; Estate Tax Reimbursement & Apportionment Provisions, Gift Tax Introduction & Overview of Generation-Skipping Transfer Tax
More Info

Linas Sudzius
March 18, 2021 3:00PM ET - 4:30PM ET ET
Private Letter Ruling 202031008 Opens Multiple Annuity Planning Opportunities
More Info

Paul Hood
March 18, 2021 1:00PM ET - 2:30PM ET ET
Part 5 of Paul Hood's Six-Part Series on the Federal Transfer Tax System: Selected Gift Tax Topics; Overview of Generation-Skipping Transfer Tax
More Info

Paul Hood
March 19, 2021 1:00PM ET - 2:30PM ET ET
Out of the Hood: Analysis With An Attitude©: Overview of Estate Planning From 30,000 Feet
More Info
![]() |
![]() |
Michael Liebeskind Bryan Bloom
March 19, 2021 3:00PM ET - 4:30PM ET ET
Private Placement Life Insurance (PPLI) and Private Placement Annuities (PPA) - A Major Tax Planning Opportunity for HNW Clients in 2021
More Info

Eric Green
March 25, 2021 1:00PM ET - 2:30PM ET ET
The Biggest Mistakes Made During Tax Season that Trigger IRS Enforcement!
More Info

Paul Hood
March 25, 2021 1:00PM ET - 2:30PM ET ET
Part 6 of Paul Hood's Six-Part Series on the Federal Transfer Tax System: Valuation: General Principles
More Info

Mark Merric
March 26, 2021 3:00PM ET - 4:30PM ET ET
Understanding Tax Provisions in An LLC Operating Agreement - Formation Concepts Part 2: Capital Accounts Compared to Stock
More Info

Paul Hood
April 01, 2021 1:00PM ET - 2:30PM ET ET
Family Business Succession Planning-It’s a Contact Sport!!!
More Info

Steve Oshins
April 02, 2021 1:00PM ET - 2:30PM ET ET
The Spousal Lifetime Access Trust: A Gifting and Creditor Protection Technique, What Advisors Need To Know for 2021
More Info
