Income Taxation of IDGT Sales and Promissory Notes During Life and After Death
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
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