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    Essential Issues to Consider with Intra-Family Debt Post-Historic Low Interest Rates

    Essential Issues to Consider with Intra-Family Debt Post-Historic Low Interest Rates
    CLE 90 min

    Essential Issues to Consider with Intra-Family Debt Post-Historic Low Interest Rates

    A popular tool in estate planning is the installment sale to an intentionally defective grantor trust. In a typical transfer, the consideration paid by the trust is in the form of a mid-term or long-term promissory note, with the annual interest rate set at the applicable Federal rate.  In this presentation we will discuss potential tax and nontax matters raised by these low rates.

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    Starting in March 2020, as a result of emergency actions taken by the Federal Reserve, the applicable Federal rate plummeted to record lows, and those low rates continued until early in 2022. Some taxpayers undertook planning to take advantage of these historic rates (e.g., engaging in new sales or making intrafamily loans, both of which are the subject of increases scrutiny by the IRS and raise issues targeting in Greenbook proposals); others refinanced existing obligations, in the same way that many did with home and car loans. In this 90 minute presentation, the presenters will discuss potential tax and nontax matters raised by these low rates, including:

    1. The Use of Intra-Family Credit in Estate Planning and Related Issues
      • Installment Sales to Intentionally Defective Grantor Trusts
      • Intrafamily Loans
      • Valuation of the Obligation (At Issuance and After)
      • Refinancing Intrafamily Obligations
    2. Gift Tax and Estate Tax Reporting Considerations
    3. Potential Legislative / Regulatory Changes

    The ABA will seek 1.5 hours of CLE credit in 60-minute states, and 1.8 hours of CLE credit for this program in 50-minute states. Credit hours are estimated and are subject to each state?s approval and credit rounding rules. Please visit www.americanbar.org/mcle for general information on CLE at the ABA.

    Product Details

    Product Code

    RP2210TUCOLC

    Duration

    90

    Publication Date

    10/3/2022 12:00:00 AM

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