Central Intelligence – March 2022

We kick off this edition of AM News with the latest updates from recent court cases relevant to our industry, and then look at rising interest rates and their impact on estate planning. Central Intelligence (CI) breaks down what we do and don’t know from several recent cases and closes with a look at current interest rates. The most discussed case of this month is, without a doubt, Estate of Levine — the latest in a series of intergenerational split-dollar cases, with this one resulting in an unequivocal win for the taxpayers. 

This issue includes:

  • US Tax Court Considers Estate Value of Intergenerational Split Dollar Receivable in Fact-Specific Case
  • US District Court includes full death benefit received on the death of an owner in the value of the decedent owner’s interest for estate-tax purposes
  • Court of Appeals denies estate charitable deduction as not ascertainable and not made by the estate
  • Tax Court disregards intermediate transfers in prearranged plan to increase gift-tax exemption
  • US District Court dismisses counterclaim of fraudulent loans to avoid federal transfer taxation
  • Appeals Court rules state law nullifies all gifts to child of divorced spouse