Thursday, January 17, 2013

Estate and Gift Tax Provisions of the American Taxpayer Relief Act of 2012

The ATRA was passed by Congress on January 1, 2013 and signed by Pres. Obama on January 2, 2013.  ATRA makes several important changes to the transfer tax system effective for individuals dying or making gifts after 2012, including the following:

1.     The exemption from estate, gift, and generation-skipping transfer tax is permanently set at $5 million (instead of the scheduled $1 million amount) as indexed for inflation after 2011.  The 2013 inflation adjusted exemption increases to $5.25 million, up from $5.12 million in 2012.  The permanent increase makes irrelevant the much discussed concern over the potential "clawback" of tax benefits associated with making a gift in an amount larger than the future estate tax exemption.

2.     The top estate and gift tax rate is permanently set at 40% (instead of the scheduled 55%), up from 35% in 2012.

3.     The flat generation-skipping transfer tax rate is permanently set at 40% (instead of the scheduled 55%), up from 35% in 2012

4.     The portability election for a deceased spouse’s unused exemption amount is made permanent (instead of expiring).

5.     The gift and estate tax regimes are permanently reunified.

With respect to ordinary income (O.I.) tax rates applicable to trusts and estates, ATRA left the 2012 rates in place except that the top 35% rate is eliminated in favor of a top 39.6% rate.  Therefore, there isn’t an intermediate 35% trust and estate income tax rate bracket in 2013 as there is for individuals.

2012 Rate Bracket
2012
 2013 Rate Bracket
2013
$0 to $2,400
15%
$0 to $2,450
15%
$2,401 to $5,600
25%
$2,451 to $5,700
25%
$5,601 to $8,500
28%
$5,701 to $8,750
28%
$8,500 to $11,650
33%
$8,751 to $11,950
33%
$11,651 and up
35%
$11,951 and up
39.6%

With respect to long-term capital gain and qualified dividend income tax rates applicable to trusts and estates, rules similar to individuals will apply.

LTCG and Qualified Dividend
2012
2013
15% O.I. rate
0%
0%
25% through 33% O.I. rates
15%
15%
39.6% O.I. rate
15%
20%

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