Estate of Rowland – An Important Federal Estate Tax Case Concerning Portability

Given that asset values tend to increase over time, and Federal estate tax liability tends to arise more on the death of a “second-to die” spouse than on the death of a “first-to-die” spouse, portability can be a critical concept to minimize Federal estate tax liability. Additionally, Revenue Procedure 2025-28 is relevant for taxpayers seeking to amend their tax returns for taxable years 2022 through 2024 and claim a 100% full deduction of their “domestic research or experimental expenditures” in those taxable years.

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The 2025 Tax Act – Key Individual Tax Provisions

Whether it is called by its popular name, the “One Big Beautiful Bill Act”, or by its official legal name, “An Act . . . To provide for reconciliation pursuant to title II of H. Con. Res. 14”, the legislation enacted by Congress on July 3, 2025 and signed into law by President Donald Trump on July 4, 2025 (the “2025 Tax Act”), will have a significant impact on taxpayers. This article describes the key individual tax provisions of the 2025 Tax Act.

“Related Party” Transactions

This article focuses on “related party” transactions under Internal Revenue Code Section 267(a)(1) and Internal Revenue Code Section 1239(a). While there is some overlap, it should be noted that the specific scope of “related parties” for purposes of a “related party” transaction under Internal Revenue Code Section 1239(a) is different than the specific scope of “related parties” under Internal Revenue Code Section 267(a)(1).

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The SLAT – A Possible New Estate Tax Planning Technique for Married Couples

Effective estate tax planning often involves two competing objectives. On one hand, there is an objective to remove assets from a person’s taxable estate, so that estate tax liability can be reduced on such person’s death. On the other hand, there is an objective to retain the income and principal from a person’s assets, so that such person’s activities are not disrupted during such person’s lifetime.

Trump’s Tax Proposals

President-elect Trump has proposed various new specific exemptions from income tax liability. First, he would exempt tips from income tax liability. Second, he would exempt overtime pay from income tax liability. Third, he would exempt Social Security benefits from income tax liability. There is no guarantee that some or any of President-elect Trump’s tax proposals will be enacted into law.

Private Foundations – Know the Advantages and Benefits But Understand the Possible Penalties

Charitable activities are favored under the Internal Revenue Code. The income of a charitable entity can be subject to favorable income taxation, and transfers to a charitable entity can realize income tax and estate tax deductions. One type of charitable entity is a private foundation. This letter refers to the “private non-operating foundation.”

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