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The Biden 2024 Budget Proposal and Its Acute Impact

The Biden Administration recently released its fiscal 2024 revenue proposals which address many radical changes that would significantly impact high net worth individuals. While it is impossible to predict what will actually get passed, especially given that the House and the Senate are nearly equally divided between the parties, it is imperative that possible changes in the law continue to be closely monitored.

Clients participating in our Client Care Program (CCP) will be receiving a comprehensive explanation of these proposals, many of which will be effective upon enactment, and advice regarding actions to consider taking now. If you are a client and haven’t already, please join our Client Care Program to receive this important explanation and advice, as well as ongoing coverage of legislative developments as they emerge.

The CCP explanation covers the significant changes proposed to be made to the following and more:

· Treatment of transfers of appreciated property by gift or upon death as realization events

· Grantor retained annuity trusts (GRATs)

· Valuation of promissory notes

· Marketability and minority interest discounts

· Wandry and similar clauses

· Reporting requirements for trusts

· Taxation of intentionally defective grantor trusts (IDGTs)

· Grantor trust planning

· Repurchase or swap of assets from grantor trusts

· Federal gift taxation of a payment of income tax on a grantor trust

· Length of generation skipping transfer (GST) tax exempt dynasty trusts

· Allowable beneficiaries of generation skipping transfers

· Ability to leverage dynasty trusts by engaging in sales from nonexempt trusts

· Required payments made by charitable lead annuity trusts (CLATs)

· Treatment of loans made by a trust to a trust beneficiary as a distribution for income tax purposes

· Limitations on annual exclusion amount

· Special use valuation.

Please contact Paul at if you would like to join the Client Care Program or schedule a meeting to further discuss the foregoing.

DISCLAIMER: We provide the information in this email for general information purposes only, and these materials do not constitute legal or other professional advice. We do not accept any responsibility for any loss that may arise from reliance on the information contained herein. No reader should act or refrain from acting based on information contained in this email without seeking advice of counsel.

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