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Prior transfers may yield present tax benefit via a credit

Article Abstract:

Estate planners should consider taking advantage of the tax credit available for prior transfers (TPT credit) when it is possible that the transferor and the receiver could die within a few years of one another. The TPT credit is aimed at avoiding double taxation of the estate assets when two owners' deaths occur in close succession. It is not required that the original owner of the estate die before the receiver, so some opportunity for sheltering assets is available. Examples are given.

Usage, Transfer (Law), Tax credits

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Drafting revocable trusts to facilitate a stepped-up basis

Article Abstract:

A step-up basis for the property of a married couple who have divided assets can be obtained upon the death of the first spouse if the assets are in a revocable trust and each spouse has general power of appointment over the other spouse's assets. The gross value of the estate will be increased, but the deceased spouse's unified credit and the marital deductions can be used to offset the increase of the estate. Scenarios are discussed.

Management, Transfer taxes, Basis (Taxation)

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Estate tax planning for nonresident alien business owners

Article Abstract:

Non-resident aliens who own businesses need to anticipate gift and estate tax liability concerning business they conduct in the US. Non-resident aliens are defined as people who can demonstrate they have not abandoned residence outside the US. These people or their advisors should consult tax treaties to determine which gift and estate taxes are covered by treaties that supersede Internal Revenue Code regulations.

Corporate Taxes, Aliens, Taxation, International business enterprises, Multinational corporations, Gift tax, Non-resident aliens, Nonresident aliens

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