Given the new estate tax environment, when should a 706 be filed for a non-taxable estate—even if not required—to take advantage of QTIP and portability elections? The balance between income tax and estate tax issues. The determination will play a pivotal role in the sub-trust funding. Dive into subtrust funding on the death of the first spouse in the context of a joint revocable trust; the effects of different estate planning techniques on subtrust funding; spreadsheets for subtrust allocation; and analyze a hypothetical fact pattern using spreadsheets. The course will also cover income tax issues related to funding; opportunities presented by QTIP; portability elections; marital deduction and generation-skipping formulae; and stale trust funding.
• Recognize portability and QTIP elections and the effect on subtrust funding.
• Affect of the 11.4 million exemption on the Trust Administration.
• Determine the targeted dollar amounts to be put into subtrusts and use spreadsheets to do the same where there is a three trust division.
• Understand the marital deduction and generation-skipping formulae.
• Identify particular assets to be put into different subtrusts and consider the rationale for each particular subtrust.
• Determine how to use of hypothetical facts in funding.
• Delaware Tax Trap for step-up in basis
• Affect pf potential deemed sale at death and no step-up in basis
• Portability elections and QTIP elections timing
• Affect of potential change in exemption and affect on administration
• Timing of funding
• Allocation of the family residence
• Dealing with large IRAs
• Stale trust funding
CPAs, attorneys, tax professionals and trust or estate planners.
General knowledge of income, estate and gift taxes.
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