Latest news with #estateTax
Yahoo
03-07-2025
- Business
- Yahoo
Who Won and Lost in Trump's Tax Bill
(Bloomberg) -- Business investors and wealthy Americans are among the biggest winners in President Donald Trump's tax bill. Those hit the hardest by the sweeping package include elite universities, who face new levies, and immigrants. NYC Commutes Resume After Midtown Bus Terminal Crash Chaos Struggling Downtowns Are Looking to Lure New Crowds Massachusetts to Follow NYC in Making Landlords Pay Broker Fees Foreign Buyers Swoop on Cape Town Homes, Pricing Out Locals What Gothenburg Got Out of Congestion Pricing The House is on track to pass the bill Thursday with Republican votes just a day ahead of Trump's self-imposed July 4 deadline. Here's who won and who lost in the legislative centerpiece of the president's domestic agenda: Winners Multimillionaires The rich gain the ability to pass more wealth on to their heirs and dodge a tax increase. The bill includes $4.5 trillion worth of tax cuts, according to a Saturday estimate from the Joint Committee on Taxation. The estate tax exemption rises to $15 million for individuals — totaling $30 million for married couples — and then adjust with inflation. The 2017 Trump income tax rate cuts also become permanent, with benefits skewing toward the wealthy. Residents of High-Tax States The limit on the state and local tax deduction rises to $40,000 annually for a five-year period. The write-off phases out for taxpayers who make more than $500,000 per year. After the five-year period, the limit snaps back to the current $10,000 limit imposed in the 2017 tax law. Small Business Owners The 2017 law that allowed pass-through business to deduct up to 20% of their qualified business income from their taxable income is permanently extended beginning in the tax year 2026. The deduction is available to owners of sole proprietorships, LLCs and partnerships. Private Equity The carried interest tax break benefiting private equity, venture capital and real estate partnerships is maintained, despite the president's push to eliminate it. Private equity also won an expanded interest expensing tax break. Domestic Car Dealers Up to $10,000 a year in loan interest for US-made cars becomes tax deductible through 2028, a boon to auto dealers looking to close sales. But the break phases out slowly for individuals with more than $100,000 in income and couples with more than $200,000. Manufacturers The bill revives several favorable tax rules for businesses, including bonus depreciation for the cost of production upgrades and a research and development tax break, winning the endorsement of the National Association of Manufacturers. The final legislation makes permanent those breaks, which were temporary in an earlier version of the bill that passed the House in May. Fossil Fuel Producers Industries like coal, oil and natural gas win tax breaks and new requirements to open up more federal land for drilling, while breaks for competing clean energy technologies are phased out. Elderly and Tipped Workers In a nod to some of Trump's populist campaign promises, taxpayers 65 and older get a larger standard deduction, while tips and overtime pay are exempted from income taxes. The provisions include limits to shrink their cost and expire after 2028. Parents The maximum child tax credit increases by an additional $200 from $2,000 starting in tax year 2025 and is permanently indexed to inflation. Parents could open up new 'Trump accounts' for their babies seeded with $1,000 from the government for children born from 2025 through 2028. Telecommunications The bill auctions off a massive amount of radio spectrum for use in wireless broadband, a potential boon for services like SpaceX's Starlink and 5G and future 6G mobile networks. Corporations Other tax increases that had been considered that would have hit big business, such as an increase in the stock buyback tax or a limit on the state and local deduction for corporations, were mostly rejected. Defense Contractors The package boosts defense spending by $150 billion, with much of the funding going to new weapons systems made by major contractors. Space The bill provides nearly $10 billion to fund projects including efforts to reach the Moon and Mars and eventually decommission the international space station. Losers Low-Income Americans Some of the costs for the tax bill are defrayed through cuts to Medicaid health coverage and food stamps, both of which benefit low-income Americans. On average, the legislation will cost the bottom 20% of taxpayers $560 a year, according to a Yale Budget Lab analysis. The measure creates new work requirements for Medicaid recipients, unless they are elderly, disabled or have children under 14 years old. Medicaid beneficiaries who gained eligibility through the Affordable Care Act will have to pay a share of costs through charges like co-pays. Food assistance for low-income Americans is cut by expanding existing work requirements for federal food stamps to cover beneficiaries up to 65 years old. Beginning in 2028, states also are required to pay a portion of food benefit costs, which are now fully paid by the federal government. Renewable Energy Clean energy industries are hit by the Republican plan, which rolls back many provisions of former President Joe Biden's landmark climate law. A tax credit for solar panels and wind systems is quickly phased out, though the legislation takes more time to eliminate other clean electricity production and investment credits. Tax credits for energy efficiency home improvements and residential installation of solar or other clean energy upgrades are eliminated at the end of the year. Technology Companies The Senate squelched a controversial effort in the bill to prevent US states from regulating artificial intelligence, delivering a win for tech industry critics and a blow to the likes of Microsoft Corp. and Meta Platforms Inc., as well as venture capital firms like Andreessen Horowitz. Trump administration officials and GOP allies in Silicon Valley had pushed the measure saying it would prevent a patchwork of cumbersome state-by-state regulations. Electric Vehicle Makers Tesla Inc., General Motors Co. and other electric vehicle makers are hit by elimination of a consumer tax credit of up to $7,500 for the purchase of electric vehicles. Elite Universities Add tax bills to the escalating battle the Trump administration is waging against elite universities such as Harvard and Columbia. The current 1.4% tax on net investment income of private college and university endowments ratchets up for better-funded institutions. The new tiered tax rate structure climbs as high as 8% for colleges with the most endowment income per student. Immigrants Several provisions raise taxes on immigrants. That includes a new 1% tax on transfers of money to foreign countries, known as remittances. Many immigrants in the US send money to relatives in their countries of origin. The proposal also restricts some immigrants' access to tax credits for health coverage premiums. The change prevents many immigrants granted asylum or temporary protected status from accessing those credits. Gamblers Gamblers would only be able to deduct 90% of their losses against their winnings, leading to a situation where they could still owe income tax if they break even over a year or lose money overall. --With assistance from Alicia Diaz and Erik Wasson. SNAP Cuts in Big Tax Bill Will Hit a Lot of Trump Voters Too How to Steal a House America's Top Consumer-Sentiment Economist Is Worried China's Homegrown Jewelry Superstar Pistachios Are Everywhere Right Now, Not Just in Dubai Chocolate ©2025 Bloomberg L.P. Error in retrieving data Sign in to access your portfolio Error in retrieving data Error in retrieving data Error in retrieving data Error in retrieving data
Washington Post
30-06-2025
- Business
- Washington Post
Republicans no longer want to repeal estate taxes. That's weird.
Ray D. Madoff is a professor at Boston College Law School and author of the forthcoming 'The Second Estate: How the Tax Code Made an American Aristocracy.' The Trump administration's 'big' tax bill has one curious omission: estate tax repeal. Ending the estate tax has been a signature issue for Republicans since the 1990s. And yet today, with Republicans controlling both Congress and the presidency, there has been hardly a whisper in support of repeal. Instead, the bill has proposed a permanent exemption amount of $15 million per person: a large number, to be sure, but one that does little for the centimillionaires, billionaires and centibillionaires who dominate our world today.
Wall Street Journal
18-06-2025
- Business
- Wall Street Journal
Trump Bill Would Raise Estate Tax Exemption to $15 Million and Make It Permanent
The big tax-and-spending bill in Congress would end a race against time by the wealthy to avoid estate taxes. The bill passed in the House last month and the Senate Finance Committee proposal released Monday both would permanently allow people to hand their heirs $15 million without paying a dime. Under the current rules laid out in the 2017 tax law, today's nearly $14 million exemption would expire at year-end and drop by about half.
Forbes
03-06-2025
- Business
- Forbes
5 U.S. Estate Tax Surprises For Nonresident Alien Investors
Foreign investors can win big with United States investments. While holding U.S. assets can be lucrative, the U.S. estate tax regime is complex and often misunderstood by nonresident alien investors. NRAs, those who are neither U.S. citizens nor residents for estate tax purposes, are often very surprised when they learn of the challenges imposed by the estate tax rules. This article summarizes 5 estate tax surprises that often catch the NRA investor off-guard. These include the limited exemption amount, common misconceptions about asset types, the requirement to disclose the value of worldwide assets on the NRA's estate tax return, and other pitfalls that can complicate estate planning. One of the biggest surprises for NRA estates is the paltry $60,000 exemption amount for U.S. situs assets subject to estate tax. U.S. citizens and residents are taxed on the value of their assets owned worldwide, but they benefit from a very generous $13.61 million federal estate tax exemption (as of 2025), and under the Trump Administration, this may rise to an inflation-indexed $15 million in 2026. NRAs are limited to a mere $60,000 exemption for U.S. situs assets. This means that if the total value of an NRA's U.S. situs assets exceeds $60,000 at the time of death, the excess is subject to U.S. estate tax at rates ranging from 18% to 40% based on a progressive table, with amounts exceeding $1 million taxed at the 40% rate. Wealthy foreign investors typically hold significant U.S. assets such as real estate, stocks, or business interests. For them, the low exemption amount can result in substantial estate tax liability that could have been mitigated with proper advance planning and structuring. The harsh effect of the estate tax can be seen for example, by an NRA with $1.5 million in non-exempt U.S. situs assets. Assuming no treaty applied to reduce the tax and no deductions are taken, the estimated U.S. estate tax would be a punishing $532,800 (a tax hit that is over 35% of the U.S. investments, significantly eroding their value). A very common source of confusion arises when identifying which assets are subject to, or exempt from, U.S. estate tax. Many NRAs mistakenly believe that cash-related holdings are exempt from the estate tax. They do not appreciate the subtle but highly important nuances. For example, bank deposits in a U.S. bank are generally not considered U.S. situs assets due to special rules. They are thus exempt from U.S. estate tax, provided they are not connected to a U.S. trade or business. Typically, this exemption applies to cash held in checking or savings accounts, certificates of deposit, or similar instruments. Many NRAs mistakenly assume this exception applies to cash held in a U.S. brokerage account but are shocked to learn that this cash is treated differently. It is considered a U.S. situs asset subject to the estate tax. Estates of foreign uninformed investors will be faced with a surprise estate tax bill since the tax law's distinction transforms what seems like a 'safe' cash holding into a taxable asset. The U.S. estate tax treatment of U.S. stocks, U.S. mutual funds, U.S. ETFs, and similarly structured U.S. vehicles is clear. These are U.S. situs assets subject to estate tax, regardless of where they are held. It will not be a shield from U.S. estate tax simply because the assets are held in a foreign brokerage account, or in the name of a nominee. Furthermore, the custodian will usually not release the assets to heirs without receiving what is called a Federal Transfer Certificate or other proof that U.S. estate tax has been fully paid. It can sometimes take well over a year for the NRA's U.S. estate tax return on Form 706-NA to be filed, tax paid and the matter to be fully resolved with the IRS. This rule can and does, trap NRAs who hold substantial U.S. investment portfolios of through international accounts. Too many foreign investors are unaware of this exposure until it's too late. This is why advance planning should be undertaken. For example, use of a properly formed estate tax 'blocker' is often a simple and beneficial solution. Perhaps one of the most jarring surprises for NRA estates is the requirement to disclose the value of the decedent's worldwide assets when filing the U.S. estate tax return. Only the assets treated as located within the U.S. are subject to the estate tax, but the IRS requires a complete picture of the decedent's global estate to determine the computation of the tax. This requirement is often viewed as very intrusive and if more investors were aware of it, they might reconsider U.S. investments or at least, implement ownership structures to avoid the estate tax. The disclosure of worldwide asset value is required for the IRS to determine whether certain deductions and treaty-based benefits may apply and specifically to calculate the amount of allowable deductions under a special proportional deduction rule. If the estate wants to benefit from these, the disclosure must be made. Although the worldwide disclosure is technically required only if the estate claims deductions or treaty benefits, omitting the information can possibly cause the return to be treated as incomplete. This can jeopardize the estate's ability to claim any of these benefits at a later time, for example, on audit. As such, full disclosure of the value of the decedent's worldwide asset value is generally the safest course. Sophisticated investors often use blocker structures, for example, holding U.S. assets through a foreign corporation. This permits the investor to avoid U.S. estate tax entirely. At death, the decedent owns shares in a non-U.S. corporation. Since shares of a foreign corporation are generally not U.S.-situs property, they are not subject to U.S. estate tax. By holding the U.S. assets indirectly through such entities, NRA investors can avoid both the estate tax on death and the intrusive requirement to disclose worldwide assets. Such strategies are commonly used by high-net-worth individuals who want to tap the U.S. market but wish to avoid triggering the U.S. estate tax regime. Think you're good because of a treaty? Think again! Another unwelcome surprise for the foreign estate lies in the limited scope of estate tax treaties. It is true that the U.S. has estate tax treaties with certain countries to mitigate double taxation, but too often they provide less relief than expected, and as discussed, claiming treaty relief means significant disclosure about the value of worldwide wealth. Some treaties allow for a prorated exemption based on the ratio of U.S. situs assets to worldwide assets. For high-net-worth taxpayers, this may not significantly reduce the U.S. estate tax burden. Complications also when the decedent's home country also imposes estate or inheritance taxes on the assets. Quite often there is a mismatch and the lack of coordination between the two tax systems can lead to double taxation, unless specific treaty provisions apply. The foreign estate may be surprised to find that the home country's tax authorities and the IRS both claim a share of the estate. Careful planning is needed when foreign laws and U.S. laws overlap and sometimes collide. Many possibilities exist, including ownership structures and certain investments, but taxpayers must be proactive in learning and implementing the plan beforehand. For example, one lesser known but welcome surprise is the treatment of life insurance proceeds paid out on an NRA's life. Even if paid by a U.S. insurer, these proceeds are typically exempt from U.S. estate tax. The use of such insurance can provide a robust planning tool for NRAs with significant U.S. assets since the life insurance can provide liquidity to cover the U.S. estate tax without itself being taxable. Get the proper advice so that efficient planning strategies are not overlooked! Stay on top of tax matters around the globe. Reach me at vljeker@ Visit my U.S. tax blog
Forbes
01-06-2025
- Business
- Forbes
U.S. Estate Tax Follows Expatriates Under Section 2801
T Tina Turner (Photo by Blick/RDB/ullstein bild via Getty Images) ina Turner's death in May 2023 sparked an interesting consideration for the estates of expatriates. She relinquished her citizenship in late 2013, approximately ten years before her death and resided in Switzerland at her death. Despite being a noncitizen of the U.S. at her death, Turner may have been subject to U.S. income and estate taxes depending upon whether she was considered a covered expatriate and whether she had assets that would be considered U.S. assets taxable in her estate. The impact of the estate tax could deplete 40% of the assets subject to tax at her death. Given her substantial wealth, it is likely that she engaged in significant planning that minimized or eliminated any tax exposure regardless. However, if she had made transfers either during her lifetime or at death to any U.S. beneficiaries, significant tax compliance and payment obligations could have resulted for both the beneficiaries and her estate. The following is a brief overview and some of the common considerations for expatriates in similar situations where they may not consider having the U.S. tax system apply even where they have no direct investments in the U.S. IRC Section 2801 imposes a tax on U.S. citizens or residents on the receipt of "covered gifts" or "covered bequests" from individuals who fall within the definition of a covered expatriates. The tax is imposed on all transfers, whether during the expatriate's lifetime or at death, as an estate tax. The law provides that the individual would be a covered expatriate if any of the following apply: (1) Had an average annual net income tax liability exceeding a specified threshold aligned with an inflation adjusted amount for five years preceding the date of expatriation, (2) Had a combined net worth of $2 million or more on all assets globally on the date of expatriation, or (3) Was noncompliant with U.S. tax obligations for five years preceding expatriation. Tax obligations extend beyond income tax to certain excise taxes as well that may be considered with personal income tax obligations. Section 2801 imposes the highest estate tax rate in effect at the time of the gift or bequest. This rate is currently 40%. In January 2025, the U.S. Congress issued final regulations on the taxation of gifts and bequests from covered expatriates. These regulations introduced the filing of a new Form 708 to report these transfers. Form 708 must be filed by U.S. recipients of covered gifts or bequests by the 15th day of the 18th month following the end of the year in which they received the covered gifts or bequests. Noncompliance subjects the recipients to significant penalties. The trust classification controls whether transfers made to trusts by covered expatriates fall within the purview of the reporting requirements and tax: In addition to other factors, compliance and tax exposure for transfers from covered expatriates should be considered in structuring trusts and making elections. Regulations under Section 2801 were passed nearly seventeen years after the statute and the scope of some provisions, especially their retroactive applicability remains uncertain. To prevent cumbersome audit issues and potential noncompliance complications, it is prudent to consider: Continued increase in expatriation makes consideration of the broader tax implications and application of covered expatriate rules significant. Celebrities and public figures face additional challenges in terms of asset location and valuation because of rights of publicity (name, likeness, and image rights) which may be deemed to be located in the U.S. even though all their assets are abroad. These issues also arise with other intangibles such as cryptocurrency, artificial intelligence, and technology. Careful asset protection and planning well before any expatriation can be critical to avoid unexpected surprises.
