A New Array of Problems and PossibilitiesA New Array of Problems and Possibilities

The year 2014 left estate planning and estate and trust administration professionals with much to ponder. Among many interesting and noteworthy developments last year:

• President Obama floated a new proposal to create a $50,000 per donor category of annual exclusion gifts without qualitative restrictions.¹ The quid pro quo would be that transfers triggering Crummey powers and gifts of interests in many closely held entities would no longer qualify for the annual exclusion.

• The Internal Revenue Service issued final regulations on Internal Revenue Code Section 67 delineating the circumstances under which costs incurred by estates and trusts are deductible for income tax purposes without regard to whether they exceed, in the aggregate, 2 ...