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IRS Issues its 2025 Revenue Proposals

Policy priorities in the estate and gift arena.

The IRS has published its revenue proposals, noting its policy priorities in the estate and gift arena, many of which continue from prior years:

  • Changing generation-skipping transfer (GST) rules applicable to trusts that are defined as non-skip persons because they include a charitable beneficiary.
  • Implementing rules to restrict the structure of payments to charitable lead annuity trusts (CLATs) to avoid deferring charitable payments at the expense of the charities.
  • Treating loans to beneficiaries from GST trusts as distributions for GST and income tax purposes.
  • Requiring a minimum remainder value of 25% and a term of 10 years for grantor-retained annuity trusts, among other types of trusts.
  • Prohibiting discounting the estate tax value of promissory notes issued at the minimum applicable federal rate for income tax purposes.
  • Treating carried interests as ordinary income.
  • Prohibiting the deferral of gain on the exchange of real property used in a trade or business under the like-kind exchange rules and instead treating the gains from the exchange that exceed a certain threshold as a sale.


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