Posts Tagged ‘estate tax’

Estate Planning Mistakes Made By the Rich and Famous

Monday, May 16th, 2011

Howard Hughes, worth billions at his death, did not have  a properly executed Last Will and Testament.  Though there were 30 purported Wills offered for probate, not one of these Wills was actually admitted to probate.  As a result,  state law determined how the wealth would be distributed, costing his estate hundreds of millions in state and federal estate taxes, which could have been avoided.  Unfortunately, Howard Hughes’ beloved Howard Hughes Medical Institute was not a beneficiary of his estate, which could have allowed Hughe’s estate to pass estate tax free due to the unlimited charitable deduction that would have been available.

The late U.S. Supreme Court Chief Justice, Warren Burger, from the highest court in America, wrote his own Will in 176 words.  As a result, his estate paid a few hundred thousand dollars in additional taxes and probate costs.  Why?  Chief Justice Burger was a brilliant attorney, but did not master estate planning 101. 

Heath Ledger had a well drafted and  properly executed Will.  However, he forgot to update his Will after the birth of his daughter, Matilda.  Fortunately, Heath’s parents have assured she will be taken care of and under the law she will become a  pretermitted heir, which means that she will ultimately be a beneficiary of his estate.  However, Heath wasn’t able to establish the terms surrounding Matilda’s receipt of the money.  In addition, Matilda’s mother will most likely not be provided for since there are no legal provisions in place for unmarried partners.       

Michael Jackson’s Will paid an unnecessary $100 mm in taxes due to poor structuring of his assets and drafting of his Will. 

Bottom Line:  A Will encapsulates your legacy.  Cutting corners, not paying attention to the details, not reviewing it regularly and updating it when necessary, or doing it on the cheap may result in negative unintended consequences.

Always Asking, Never Assuming™

Christopher Holtby

Beschäftigen Sie Besitzrechtsanwalt

Thursday, December 31st, 2009

That is a long title, in German, for estate attorneys in the upcoming year (I spoke German growing up, as my mother and grandparents are Austrian).  The estate planning world is in a state of flux.  On 1/1/2010, the gift tax drops to 35% (it’s currently 45% and increases to 55% on 1/1/2011 based on current law).  The gift tax is calculated on the tax-exclusive basis, making it a more tax-efficient transfer process than waiting to pay the estate tax rate.   For taxpayers living more than 3 years from the date of the taxable gift, only the value of the interest transferred will be used to calculate the deceased’s taxable estate.  For taxpayers living less than 3 years from the date of the taxable gift, the gift tax paid will be included in the deceased’s taxable estate.  In both cases, appreciation in the value of the gift would not be included in the taxpayer’s adjusted taxable estate (source: Leimberg).  There are some additional benefits, subject to the facts and circumstances, such as valuation differences between assets transferred and the value of the interest itself.

As the weeks unfold (Congress reconvenes Jan 5, 2010), clients should be discussing with their estate attorneys how their current wills and wealth transfer strategies align with current rules that take effect 1/1/10 and potential new rules.  Many estate plans written over the last few years had flexibility added to documents using disclaimers, etc.  Clients should discuss the timing of pre-planned taxable gifts, the effects on children and grandchildren, GRATs, QTIPs, and CLATs.
  
Bottom line:  This is going to be a busy year for estate attorneys.
 

Always Asking, Never Assuming™

Christopher Holtby

Potentially last opportunity for some estate planning techniques

Friday, October 23rd, 2009

[Disclaimer:  I am not an attorney.   Please discuss any concepts with your attorney.   I am not liable if any of these concepts are followed without consulting an attorney and turn out badly].   

An attorney friend of mine sent an e-mail outlining several estate planning techniques which, in his opinion, are at risk of being reduced or eliminated.  Here is a short re-cap:

1) Valuation discounts for transfers of certain entities between family members (i.e. FLPs and family LLCs) could be disallowed, either in whole or in part (for example, if, hypothetically, the discount goes from a current 35% to 10% after a tax law change, for a $10 million estate, an extra $2.5 million remains in the taxpayer’s estate and is taxed at the current 45% estate tax rate).

2) GRAT (Grantor Retained Annuity Trusts) terms for a period of less than 10 years could no longer be allowed (means if the grantor dies within those 10 years, the assets are brought back into the grantor’s estate).

Bottom line: Tax levels ebb and flow as with seasons.   Since we are heading toward higher taxes, you should plan accordingly and quickly in 2009.  

 

Always Asking, Never Assuming™

Christopher Holtby