This session highlights the following estate planning current developments:

• Transfer Tax legislative proposals,
• Major planning changes under the SECURE Act,
• Proposed regulation regarding the deductibility of trust expenses and of excess deductions in the last year of an estate or trust,
• Basis adjustment planning,
• GST effects of trust modifications and planning for GST non-exempt trusts, 
• Income tax effects of terminating trust early with parties receiving their actuarial interests (PLRs 201932001-201932010),
• Tax affecting in valuing S corporations (Kress and Jones),
• Rejection of “game theory” assumptions in valuing entities (Grieve),
• The latest FLP §2036 case with its surprising analysis (Moore), and PLR 202022002 applying Rev. Rul. 85-13 (non-recognition treatment for transactions) to certain deemed owner trusts under §678. 

In addition, we will highlight special considerations for wealth transfer planning in a low-interest rate environment, including gifts of depressed assets with disclaimers as a hedge, GRAT planning (funding with depressed assets, buying back assets from depressed or appreciated GRATs, front-loaded GRATS), sales (low rate notes, refinancing notes), impact of volatility on discounts, and spreading out transfers.