#estate-planning
Estate Planning
Tax-efficient strategies for transferring wealth and business assets to the next generation
California Proposition 19 and the End of the Old Parent-Child Property Tax Bargain: A 2026 Guide for Heirs of California Real Estate
How California's Proposition 19 replaced Section 63.1 for parent-child transfers after February 16, 2021 — the family home and farm rules, the one-year occupancy requirement, the BOE-19-P and BOE-266 filings, the $1,044,586 value cap floor, and the step-up-basis trade-off that determines whether to gift during life or transfer at death.
The $15 Million Estate Tax Exemption Is Now Permanent: How High-Net-Worth Families Should Recalibrate SLATs, GRATs, and Lifetime Gifts in 2026
The One Big Beautiful Bill Act locks the federal estate, gift, and GST exemption at $15 million per individual with no sunset. Here is what changes for SLATs, GRATs, dynasty trusts, GST allocation, and basis planning in 2026 — and what to actually do this year.
Section 1041 and Divorce: A Guide to Property Transfers, Carryover Basis, and QDROs
Section 1041 lets spouses transfer property tax-free during and after divorce, but carryover basis, the six-year window, QDROs, ISO conversions, and post-TCJA alimony rules quietly reshape every settlement. A working guide to what must be fixed before the decree is signed.
Section 1235 Capital Gains Treatment for Patent Sales: How Inventors Convert Royalty Income Into Long-Term Capital Gain
Section 1235 lets individual inventors and qualifying early investors treat a patent sale as long-term capital gain — even without a one-year holding period — if they transfer all substantial rights. This guide explains who qualifies as a holder, why the rule survived the TCJA carve-out for self-created intangibles, and how to draft the transfer so the IRS sees a sale rather than a royalty license.
Form 3520-A: The March 15 Deadline, Substitute Filings, and the 5% Section 6677 Penalty
Form 3520-A is the annual information return for a foreign trust with a U.S. owner, due March 15. If the foreign trustee does not file, Section 6677 imposes an initial 5% penalty on trust assets plus $10,000 per 30-day continuation period — payable by the U.S. owner. Covers who files, the substitute filing path, the reasonable-cause defense, and how to clean up multi-year non-compliance.
Crummey Letters and ILITs: How High-Net-Worth Families Keep Life Insurance Out of Their Taxable Estate
A working guide to ILITs and Crummey powers — covering Section 2042 incidents of ownership, the annual gift tax exclusion, the 5-or-5 rule, hanging powers, the Section 2035 three-year lookback, and the administrative discipline that keeps life insurance death benefits estate-tax-free.
Form 1310 Demystified: How Surviving Spouses, Executors, and Heirs Cash a Deceased Taxpayer's Final Refund Without Triggering a Year-Long IRS Delay
Form 1310 is the IRS form survivors use to claim a deceased taxpayer's refund. This guide explains who must file, the three Part I claimant boxes, the documents to attach (and the one to keep), and how to avoid the 6–12 month delays that trap most paper filers.
Form 706-NA: The $60,000 Trap That Can Turn a Foreign Investor's U.S. Real Estate Into a 40% Estate Tax Bill
Nonresident aliens who own U.S. real estate, U.S. corporate stock, or other situs property get only a $60,000 estate tax exemption — not the $13.99 million citizens enjoy in 2026 — and pay up to 40% on the excess. A working guide to Form 706-NA, FIRPTA withholding, treaty relief via Form 8833, transfer certificates, and the blocker-corporation structures that actually work.
Section 2032A Special-Use Valuation: Cut Up to $1.46 Million Off the Estate Value of a Family Farm or Closely Held Business in 2026
Section 2032A lets executors value qualifying farm or closely held business real property at productive use rather than fair market value, with a 2026 reduction cap of $1,460,000 — worth up to $584,000 in federal estate tax at the 40% rate. The election is irrevocable, requires material participation, and triggers a 10-year recapture period.
The Section 691(c) Deduction: How IRA Beneficiaries Recover Estate Tax
Beneficiaries of taxable estates can claim a Section 691(c) income tax deduction for federal estate tax already paid on inherited IRAs and other IRD assets. This guide covers eligibility, the with-and-without calculation, where to claim it on Schedule A, and the errors that cost families six figures.
Step Transaction Doctrine: How the IRS Collapses Multi-Step Tax Plans
The step transaction doctrine lets the IRS treat a sequence of formally separate steps as one taxable transaction. This guide explains the three tests courts apply — end result, mutual interdependence, and binding commitment — the landmark cases (Gregory v. Helvering, Court Holding, Kimbell-Diamond), the 2026 transactions most exposed (1031 drop-and-swaps, pre-sale entity conversions, gifts before the estate exemption sunset), and the documentation habits that keep multi-step plans defensible.
Give It Now or Leave It Later? The Basis Trap That Quietly Costs Families Hundreds of Thousands in Capital Gains Tax
Lifetime gifts under IRC Section 1015 carry over the donor's basis, while inheritance under Section 1014 steps it up to fair market value at death — a difference that can shift a family's after-tax outcome by six figures on a single appreciated position under the 2026 $15 million federal exemption.