My partners and I are offering a FREE webinar to review what was discussed, and other key issues and planning opportunities under the Proposed Regulations on Monday, September 17that noon. The bad news that just about everything that the IRS spokespeople said confirmed the anti-taxpayer positions that the Proposed Regulations have taken. Many advisors felt that the Proposed Regulations could be read to allow for two thresholds under an ESBT, but the IRS spokespersons did not see it this way. It was also discussed that the IRS intends to “disrespect” irrevocable trusts that would be taxed as separate entities, and could otherwise deduct Section 199A income if they are under the $157,500 threshold, if formed for the purpose of avoiding income tax by use of the Section 199A deduction. If the property is owned outright by a deceased person, there is a new income tax basis which can count in the 2.5% Qualified Property calculation.

Source: Forbes September 15, 2018 20:26 UTC