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IRS Confirms Gifts Using Higher Exemption Amounts Won’t Be “Clawed back” for Estate Tax Purposes After 2025

November 21, 2019

The Treasury Department and the Internal Revenue Service have officially confirmed that in the event the federal gift and estate tax exemptions are reduced in the future, taxpayers will not be penalized with a “clawback” for the use of higher exemption amounts.

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Connecticut Quietly Ends Estate Tax Strategy Previously Available to Non-Residents

July 31, 2019

In the flurry of legislation passed in June at the end of the legislative session, Connecticut quietly closed a Connecticut estate tax loophole that was available to non-residents.    

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U.S. Supreme Court Rules in Favor of Trust on Question of State Income Taxation

June 20, 2019

On June 21, 2019, the United States Supreme Court, by a unanimous decision, held that the State of North Carolina could not impose a state level income tax on a trust based solely on the residence of the beneficiary of the trust. 

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Connecticut Real Estate Sales in Excess of $2.5 Million Will Face Additional “Mansion Tax” under New Law

June 9, 2019

The recently approved Connecticut 2020/2021 state budget includes an increase in the rate of tax charged on real estate sales in excess of $2.5 million, which is being referred to as the “mansion tax.”  This new rate structure will be effective on July 1, 2020. 

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Connecticut Enacts Historic and Sweeping Trust Legislation

June 4, 2019

The Connecticut legislature, on June 5, 2019, enacted HB 7104, an Act Concerning the Connecticut Uniform Trust Code.  This massive bill, over 90 pages in length, adopts four major categories of revisions to trust law that will greatly enhance the administration of trusts and planning opportunities for clients in Connecticut.

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The IRS Clarifies that Private Equity, Hedge Funds and Other Partnerships are Subject to Withholding Requirements When Foreign Persons are Involved

May 22, 2019

On May 7, 2019, the IRS issued proposed regulations for new code section 1446(f), which requires withholding of income tax when a foreign person recognizes gain or loss from the sale or exchange of certain partnership interests, as described in IRC 864(c)(8).

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New IRS Guidance on Opportunity Zone Investments

April 16, 2019

On April 17, 2019, the IRS and U.S. Treasury Department issued proposed regulations (Proposed Treas. Reg. Sec. 1400Z-2), that provide new guidance for qualified "Opportunity Funds" investing in "Opportunity Zones."

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Increase in New York Real Property Transfer Taxes, Including “Progressive Mansion Tax”

April 10, 2019

As part of the 2019/2020 New York State Budget Bill that was passed, New York included a progressive mansion tax with a top tax rate of 3.90% on properties purchased for $25 million or above.

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NY Extends the Three Year Look Back for Lifetime Gifts when Calculating the New York Estate Tax

April 3, 2019

The New York estate tax exemption currently is $5,740,000.  The exemption is adjusted for inflation and will increase over time.

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Client Alert - Connecticut's Changes to Estate and Gift Tax Exemptions - Confirmed!

March 11, 2019

In 2019, the Connecticut exemption amount from estate and gift tax has been increased from its prior level of $2,600,000 per individual to $3,600,000.  As we have reported, there has been some confusion as to what is to occur in 2020 and future years because in May of 2018, Governor Dannel P. Malloy and the Connecticut legislature enacted two different bills with respect to the Connecticut estate and gift tax.

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Governor Lamont’s Budget Proposal Includes Potential Changes to Connecticut’s Estate and Gift Tax

February 19, 2019

Governor Lamont’s proposed budget titled “A Path Forward” for Fiscal Year 2020 and 2021 was announced on February 20, 2019 (the “Proposed Budget”) and includes changes to Connecticut’s estate and gift tax regime.

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Beware of Scam Targeting Owners of LLCs

January 3, 2019

Connecticut clients should be aware of a large scale scam targeting owners of Limited Liability Companies. 

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