Key Developments at Heckerling 2018
The 52nd Heckerling Institute on Estate Planning covered a variety of topics as noted by the Recent Developments panel. Among the major developments covered from the prior year was the issue of how a grantor’s purchase of his GRATs remainder interest does not constitute full and adequate consideration for the purposes of the gift tax. Also discussed was how the interest on a Graegin loan may face limited deductibility when an estate retains enough liquidity to sufficiently pay owed estate taxes. Another topic of note, taxpayers continue to successfully defend their valuations of their self-cancelling installment notes despite IRS push back. And finally, in an odd twist, the Tax Court peculiarly applied section 2036(a)(2) as a means to include assets from a family limited partnership in the decedent’s estate.
See N. Todd Angkatavanich & Nickolas Davidson, Key Developments at Heckerling 2018, Wealth Management.com, January 25, 2018.
Special thanks to Jim Hillhouse (Professional Legal Marketing (PLM, Inc.) for bringing this article to my attention.