N. Todd Angkatavanich, Christine R.W. Quigley and Marissa Dungey reason how this type of CLAT can achieve multiple goals, including giving to charity, generating a current income tax deduction to offset year 2017 and providing for a potential tax-free shift of future appreciation to extended family members.
In Revenue Procedure 2014-18 issued on Jan. 27, 2014, the Internal Revenue Service announced a simplified method for certain taxpayers to make a portability election for smaller estates that didn’t timely file an estate tax return to elect portability.
In CCA 201330033, the IRS stated that the mortality tables didn’t apply to value the self-cancelling installment note (SCIN); rather the transferor’s life expectancy had to be considered in light of his particular medical history as of the date of the gift to determine the value of the SCIN.
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