Boise Office:

250 South Fifth Street
Suite 660
Boise, ID 83702
P.O. Box 9500
Boise, ID 83707-9500
p: 208.639.7799
f: 208.639.7788

Seattle Office:

1001 Fourth Avenue
Suite 4333
Seattle, WA 98154
p: 206.652.0101
f: 206.223.2230

Ahrens DeAngeli Law Group LLP

Ahrens DeAngeli Law Group LLP (ADLG) is one of the country's premier attorney groups offering services in the area of wealth planning and preservation and trust and estate law. With offices in Boise and Seattle and Of Counsel attorneys in Phoenix and the San Francisco Bay Area, we represent clients internationally and throughout the United States, many of whom are among the wealthiest families in the world. Our clients seek us out because we have built a reputation of excellence as experienced advisors in:

  • wealth planning and preservation
  • tax planning
  • business succession
  • charitable planning
  • tax exempt organizations
  • trust and estate administration and litigation
  • tax controversy
  • complex guardianship and conservatorship cases

Wealth Planning and Preservation

The aggregate wealth of ADLG's core client base exceeds $10 billion. Our dedicated team of attorneys has been structuring dynasty trust plans for more than 20 years and focusing on developing and implementing smart and creative strategies to meet our clients' goals. While tax planning is a key component of every strategy, for most of our clients the primary goal of wealth planning is not the mere "transfer of wealth." Rather, for them a successful plan instills in their heirs and successors core values and wisdom-based skills in financial and social matters that last for generations. These values and skills include:

  • business, asset and financial management
  • education
  • employment
  • philanthropy
  • volunteer and charitable activities
  • social responsibility

A plan that successfully meets our clients' goals requires creativity, flexibility and structure, and is achieved through thoughtful, deliberate discussions with the client, family members and trusted advisors.

We work closely with our clients' independent and in-house accounting, legal, and financial advisors to facilitate this dialogue. Our knowledge of income, estate, gift and generation-skipping transfer tax laws enables us to maximize the portion of an estate or trust that passes to beneficiaries.

Trust and Estate Administration and Litigation

With our extensive experience in the administration and distribution of trusts and estates, we efficiently resolve the complex issues clients face during the difficult times that follow the death of a family member. We offer objective guidance to trustees, executors and beneficiaries in contested and uncontested matters. Usually, we're able to resolve contested matters through settlement negotiations or non-judicial dispute resolution. However, when litigation is inevitable, we work closely with litigation counsel to achieve the best possible results for our clients.

Charitable Tax Planning

Our extensive charitable planning practice includes the design and implementation of charitable strategies that achieve our clients' tax and philanthropic goals. In addition, we help our clients form charitable foundations and other entities that institutionalize their family's philanthropic values for future generations.

We advise directors and trustees of charitable organizations regarding their fiduciary duties and the unique tax laws applicable to their charities. We also actively participate on the boards and committees of public and private charitable organizations.

Tax Controversy

When our clients are audited by the Internal Revenue Service or other taxing authorities, we vigorously and effectively guide them through the tax controversy process. In most cases, we negotiate settlements favorable to our clients. If needed, however, we litigate tax disputes in the U.S. Tax Court and other federal courts. Our practice covers income, gift, estate and generation-skipping tax controversy matters and includes:

  • federal, state and international tax controversy
  • Internal Revenue Service audits and appeals
  • competent authority matters
  • trial and appellate litigation

Complex Conservatorship and Guardianship Cases

We have significant experience with complex conservatorship and guardianship cases. Because these proceedings involve the potential deprivation of fundamental rights and liberties, we proceed with utmost caution to ensure that the proposed disabled person receives a fair hearing and retains all the rights and powers to which he or she is entitled.

At ADLG, our mission is to provide the highest quality legal services available in the country so our clients can achieve their wealth planning, preservation and philanthropic goals. Our creative solutions to complex issues enable our clients to positively impact their families and society for generations.

ADLG Attorneys

We are a team of attorneys dedicated to all aspects of wealth planning and preservation. We love coming to work to help our clients and their families through the tough issues surrounding wealth planning, death and taxes. Please click on any of our bios to learn more about each member of our team.

 

 

 

 

 

 

 

 

 

EDWARD D. AHRENS, P.C., Partner

Recognized as one of the top estate planning attorneys in the nation, Ed Ahrens has represented some of America’s wealthiest individuals and families during his 40-year career. Prior to the formation of ADLG, Ed led the estate planning practices of several highly respected law firms, and, as a director at Arthur Andersen, was a member of the accounting firm’s national family wealth planning specialty team. Ed is an accomplished author and speaker and has served on numerous boards of public charities and private foundations. We have been fielding a few questions about the possibility of Ed retiring from the practice. Three words: Weekend at Bernie’s.

Education:

J.D., University of Idaho (1971); Idaho Law Review
B.A. Economics, University of Idaho (1968)

Professional Recognition:

Fellow, American College of Trust and Estate Counsel
The Best Lawyers in America: Trusts and Estates & Litigation–Trusts and Estates
Martindale Hubble AV rated
Super Lawyers, Mountain States
Super Lawyers, Washington State

Professional Memberships and Civic Activities:

Charitable Committee, The Schindel Foundation
Member, Idaho Community Foundation
University of Idaho College of Law Advisory Board
Capital Campaign Committee, Sitka Tribe of Alaska
Director, Nevada State EB-5 Regional Center, Inc.

Bar and Court Admissions:

Idaho
Washington
United States Tax Court
Ninth Circuit Court of Appeals
United States District Court for the District of Idaho

Kevin M. Chen, P.C., Partner

Kevin Chen advises clients of substantial wealth across the nation on complex issues related to wealth planning and preservation, business succession, tax controversy, and trust and estate administration and litigation. Outside the office, Kevin writes on trust and estate matters, speaks to professional and civic groups and serves on the boards of various charitable and nonprofit organizations. Prior to joining ADLG, Kevin was a partner in the law firm of Kirkland & Ellis LLP in Chicago and served as a judicial law clerk to the Honorable Leonard H. Russon of the Utah Supreme Court. During his time in China, Kevin studied the works of Chinese philosophers, such as Confucius and Lao Tzu. His favorite is a lesser known philosopher, Wan Rite Wei, whose philosophical musing that "round tables make no sense" endures the test of time. Machiavelli's corollary to Wei's discussion of round tables, i.e. “unless you have a pizza” has been confusing Kevin as of late.

Education:

J.D., University of Utah (1997); Utah Law Review
B.A., English, magna cum laude, Boise State University (1992)
Universidad del Pais Vasco, Foreign Studies Program (1990-91)

Bar and Court Admissions:

Idaho
Illinois
Utah
United States Tax Court

Professional and Civic Memberships:

Boise Estate Planning Council, board member
Idaho State University Tax Institute, member of Executive Program Planning Committee
Taxation, Probate and Trust Law Section of the Idaho State Bar Association
Eastwind Community Church, past board member

Publications:

"Formula Disclaimers: Procter-Proofing Gift Revaluations By IRS," Journal of Taxation, Vol. 96, No. 4, April 2002, co-authored with David A. Handler

"Fresh Thinking About Gift-Splitting," Trusts & Estates Magazine, January 2002, co-authored with David A. Handler

"The Estate Trust Revival: Maximizing the Full Basis Step-Up for Spouses," Trusts & Estates Magazine, August 2001, co-authored with David A. Handler

"Proprietary Approaches for Planning with Individuals and Their Businesses," Cannon Financial Institute, Inc. and Kirkland & Ellis, The 2001 Estate Planning Teleconference Series, March 2001, co-authored with Glenn Kurlander

Darin DeAngeli, P.C., Partner

As an attorney and a certified public accountant for over 20 years, Darin DeAngeli has focused on all aspects of estate and wealth planning, charitable giving, charitable organizations, and business succession planning. Prior to forming Ahrens & DeAngeli, p.l.l.c. with Ed Ahrens in 1997, Darin served as a family wealth planning manager with Arthur Andersen. Darin has represented some of the wealthiest families and largest companies in Idaho and the western United States, and he is known regionally as one of the top legal advisors in matters involving charitable giving and charitable organizations. ADLG clients and colleagues appreciate Darin's experience and unique approach to complex legal issues, which always includes wit, humor and practical wisdom. Darin has recently taken up walking everywhere. It is a simple coincidence that both of his children have recently received their driver’s permits.

Education:

J.D., University of Oregon (1991), Order of the Coif; Editor-in-Chief Oregon Law Review
M.B.A., Finance/Human Resource Management, University of Oregon (1989)
B.S., Accounting, Boise State University (1987) cum laude

Professional Recognition:

Best Lawyers in America, Trusts and Estates, 2012 Boise Trusts and Estates Lawyer of the Year
Martindale Hubble AV rated
Outstanding Planned Giving Professional Award, Southwest Idaho Planned Giving Council, 2005

Other Professional Designation:

Certified Public Accountant, Idaho

Professional Memberships and Civic Activities:

St. Luke’s Hospital Foundation, Chair
St. Luke’s Treasure Valley Medical Center Board
ALS Therapy Development Institute, Volunteer
Boise Public Schools Education Foundation, President
Taxation, Probate and Trust Law Section of the Idaho State Bar Association
Idaho Veterans Research and Education Foundation, Secretary
One Stone Champions Committee, One Stone, Inc., Vice President

Bar and Court Admissions:

Idaho
Oregon
United States Tax Court

Deborah V. Dunn, Partner

Debbie joined Ahrens DeAngeli Law Group in 2012 and is actively engaged in all of ADLG’s practice areas. Debbie is a 1995 summa cum laude graduate of Brigham Young University's J. Reuben Clark Law School. Prior to joining ADLG, she was a partner with Kirkland & Ellis LLP, where she had practiced in the Chicago office since 1995. During her more than 16 years as an estate planner, Debbie has concentrated her practice on multi-generational estate planning and administration for families of significant wealth, family offices and owners of closely-held businesses. She has represented taxpayers in complex estate and gift tax audits and appeals, executors in will contests and disputes with beneficiaries, trustees with respect to trust administration, and beneficiaries with respect to rights and claims in trust and estate administration.

Of particular interest to Debbie is the design of sophisticated estate plans and creation of innovative techniques, involving life insurance, GRATs, Remainder Purchase Marital Trusts, remainder sales and the transfer of other assets to grantor trusts, and CLATs. She is the creator of several cutting-edge estate planning techniques and the author of numerous articles and publications in the estate planning field.

After living in the flat lands of America’s Midwest for over 16 years, Debbie is happy to once again be near mountains. She and her family are looking forward to becoming involved in the Boise community. Debbie, however, would like to add as a disclaimer that she did not name her daughter, Kellan, after a certain local football legend.

Education:

J.D., Brigham Young University, J. Reuben Clark Law School (1995) summa cum laude
M.A., Brigham Young University (1991)
B.A., University of Utah (1988)

Professional Recognition:

Listed: Chambers USA: America’s Leading Lawyers for Business 2011
Named: Illinois Super Lawyer 2007, 2008
Member: Chicago Estate Planning Council 2011-2012

Professional and Civic Memberships:

Gift Planning Advisory Committee for the Museum of Science and Industry, 2011-2012
Board Member of Foresight Design Initiative, 2004-2012

Publications:

Co-author of Drafting the Estate Plan: Law and Forms, Volumes I and II (CCH) (first published 2003, updated annually)

Co-author of chapter "Asset Freeze and Valuation Reduction Techniques" in Estate Planning for Illinois Attorneys: The Basics and Beyond, published by Illinois Institute for Continuing Legal Education (IICLE) (2005, 2008)

Contributing Editor of the American Bankers Association Estate Planning Manual (1998-1999)

Bar and Court Admissions:

Illinois 1995
Hawaii 1998 (inactive)
Tax Court

Articles:

Trusts & Estates Magazine:
“Bypass the Bypass Trust?” (February 2011)
“An Alternative to QPRTs” (April 2009)
“Basis Boosting” (February 2007)
“Zeroed-Out GRATs and the ETIP” (December 2004)
“Coming to a Wal-Mart Near You: Tax-Free GRATs” (April 2001)
“RPM Trusts: Turning the Table on Chapter 14” (July 2000)
“A New Twist on Sec. 2503(e): Health and Education Exclusion Trust” (July 2000)
“Retaining Testamentary Powers of Appointment” (January 2000)
“Guaranteed GRATs: GRATs Without Mortality Risk” (December 1999)

Estate Planning Magazine:
“The Incomplete Equity Strategy May Bolster Sales for Grantor Trust” (February 2007)
“The Reverse GRAT: Hoisting the IRS Upon Its Own Petard?” (January 2005)
“The LPA LID: A New Way to ‘Contain’ Gift Revaluations” (June 2000)

Tax Management Estates, Gifts and Trusts Journal:
“RPM Trusts: Reduction of Valuation Risks” (Vol. 33, No. 5, September-October, September 11, 2008)
“Guaranteed GRATs and Private Insurance” (Vol. 31, No. 6, November 9, 2006)
“Advantages to Back-Loading: An Analysis of Back-Loaded Annuity Payments from a CLAT or RPM Annuity Trust” (Vol. 29, No. 6, November-December, November 11, 2004)

Mary L. Kaczmarek, Of Counsel

Prior to joining ADLG in 2011, Mary was an associate at Skadden, Arps, Slate, Meagher & Flom LLP and Kirkland & Ellis LLP in Chicago. During her time with Skadden, Mary worked on a myriad of cases involving federal income tax issues effecting C Corporations, S Corporations, REITs and individuals. During her time at Kirkland & Ellis, Mary worked on all manner of high wealth estate planning cases utilizing wills, revocable trusts, generation-skipping transfer trusts, dynasty trusts, life insurance trusts, qualified personal residence trusts, charitable organizations and grantor retained annuity trusts where appropriate. Mary likes to play doubles tennis when time permits. ADLG was extremely excited to hire Mary for a number of reasons, one of which was that she won TWO AWARDS in college for outstanding mathematics student. Totally unrelated is the recent jump in the partners’ children’s math grades.

Education:

J.D. with honors, The University of Chicago Law School (2001)
B.A. cum laude, Mathematics, Pomona College (1998)

Bar and Court Admissions:

California (2001)
Illinois (2002)

Kellie D. Kuster, Of Counsel

Kellie Kuster is an of counsel attorney in the Boise office of Ahrens DeAngeli Law Group. Since joining ADLG in 2005, Kellie has focused her practice on structuring multi-generational estate plans for wealthy individuals and families, and on complex trust and estate administration. Kellie also is actively engaged in ADLG's charitable planning practice. As a third-generation Idahoan who has lived, attended school and worked in Idaho most of her life, Kellie has been known to entertain friends and colleagues with the game "Two Degrees of Kellie Kuster" based on the "small world" phenomenon. She has never met Kevin Bacon.

Education:

Master of Laws (LL.M.), taxation; Levin College of Law, University of Florida (2004); graduate editor Florida Tax Review
J.D., University of Idaho (2003); symposium edition editor Idaho Law Review
B.A., Political Science, University of Idaho (1990) cum laude

Professional and Civic Memberships:

Taxation, Probate & Trust Section of the Idaho State Bar
Southwest Idaho Planned Giving Council, board member
Idaho Women's Charitable Foundation

Bar and Court Admissions:

Idaho

Nicholas S. Marshall, P.C., Partner

For over 16 years, Nick's practice has been focused in the areas of estate planning, complex trust and estate administration, and charitable planning. Nick routinely deals with complex estate, gift and generation-skipping transfer tax issues as well as income tax issues associated with trusts, estates, qualified retirement plans, and IRAs. In his trust and estate administration practice, Nick represents trustees, executors, and beneficiaries in both contested and uncontested trust and estate matters, as well as the mediation and litigation of such matters. His charitable planning practice includes structured gifts and the formation of charitable trusts and private foundations. Nick is a fifth-generation Idahoan and lives in Boise with his wife, Michelle, and daughters, Emma and Zoë. Because Nick is a borderline hypochondriac, he is the healthiest person in the firm. He recently heard that laughter is the best medicine and so he tells himself, out loud, that he needs to laugh more. This makes everyone else laugh.

Education:

Master of Laws (LL.M.), taxation, New York University (1996)
J.D., University of Idaho College of Law (1995); Idaho Law Review
B.A., Economics, University of Puget Sound (1992); Omicron Delta Epsilon

Professional Memberships and Civic Activities:

Taxation, Probate and Trust Law Section of the Idaho State Bar, past chairman and member
Trust and Estates Section of the California Bar Association
American Bar Association Section of Real Property, Probate and Trust Law Section
University of Idaho Foundation, Gift Acceptance Committee
College of Idaho, Planned Giving Committee
Southwest Idaho Planned Giving Council
Boise Estate Planning Council

Bar and Court Admissions:

Idaho
California
Washington
United States Tax Court

Stephen L. Pruss, Partner

Recognized by those who know him as one of the finest and most intelligent trust and estate attorneys in the United States, Stephen Pruss has advised clients for over 25 years. Integrating his skills as an attorney and certified public accountant, Steve provides ADLG’s clients with an impressive depth of knowledge in tax, estate planning, trust and estate administration, tax controversy, and guardianship and conservatorship matters. He is also active in the community as an officer and board and committee member of several nonprofit organizations. When he's not working for his clients, Steve enjoys spending time with his wife Stacy and their families, being involved in their church, and trying to find his errant golf shots.

Education:

J.D., University of Idaho College of Law (1985), graduated first in class
B.A., Accounting and Business Administration, Northwest Nazarene University, summa cum laude (1979)

Professional Recognition:

Fellow, American College of Trust and Estate Council
The Best Lawyers in America (Woodward/White) - Selected in field of "Trusts and Estates"
Puget Sound Business Journal and Seattle Metropolitan Magazine - Recognized as a top trusts and estates attorney in the area

Other Professional Designation:

Certified Public Accountant, Idaho

Professional Memberships and Civic Activities:

American College of Trust and Estate Counsel
American Bar Association Section of Real Property, Probate and Trust Law Section
Real Property, Probate & Trust Section of the Washington State Bar Association
Taxation, Probate and Trust Law Section of the Idaho State Bar Association
Southwest Idaho Planned Giving Council, Secretary
Washington Planned Giving Council

Bar and Court Admissions:

Idaho
Washington
Federal District Court in Idaho
Ninth Circuit Court of Appeals
United States Tax Court

Theodore S. Reich, Of Counsel

Ted Reich brings 30 years of experience and a unique skill-set to ADLG clients around the world who own and manage their own businesses. His expertise is sought in many areas, including tax, generational planning and business succession matters for families of substantial wealth. Ted is a partner of Reich and Walner LLP, a certified public accounting firm in Oakland, California. Prior to forming Reich and Walner in 1996, Ted was a principal with Arthur Andersen. When Ted is not advising clients, he is active as a director of ALS Therapy Development Institute, the world's most advanced research laboratory dedicated to Lou Gehrig's disease.

Education:

J. D., Santa Clara University; Santa Clara University Law Review, comments editor (1982)
B.S., Political Science, Santa Clara University (1978)

Other Professional Designation:

Certified Public Accountant

Bar and Court Admissions:

California

Tyler J. Rice

Tyler Rice is an associate attorney in the Boise office of Ahrens DeAngeli Law Group and is actively engaged in all of ADLG’s practice areas. Tyler joined ADLG in 2013 after receiving a Master of Laws (LL.M) in taxation from the University of Florida, Levin College of Law. During the summer months of 2012, Tyler was a legal intern with ADLG and the summer prior to that, he was a legal extern for the Idaho State Tax Commission, Office of the Attorney General. Even though his wife is three inches taller than he is, Tyler does not have a Napoleon complex. Il combattra quiconque affirme le contraire.

Education:

Master of Laws (LL.M.) taxation, Levin College of Law, University of Florida Graduate Program (2013)
Juris Doctor (J.D.), University of Idaho College of Law (2011), President of Volunteer Income Tax Assistance (VITA)
Master of Science, Accountancy-Taxation, Boise State University (2011)
Bachelor of Science, cum laude Accountancy-Finance, Boise State University (2008)

Bar and Court Admissions:

Idaho
North Dakota
United States District and Bankruptcy Court, District of Idaho

Peter C. Sisson

Peter merged his elder law practice with Ahrens DeAngeli Law Group in 2014, bringing decades of experience helping seniors and their families provide for their changing legal, financial, and health care needs.

Peter is formerly the principal of Sisson and Sisson, the Elder Law Firm. He is a board-certified elder law attorney and estate planning law specialist. His professional and civic engagements include memberships in the National Academy of Elder Law Attorneys, the National Care Planning Council, the Boise Estate Planning Council, and The Idaho End-of-Life Coalition.

Peter regularly provides free educational presentations to professionals and the public on the legal, financial and health issues experienced by families who are dealing with a spouse or parent’s long-term care needs.

For more information about Peter’s background and experience, please visit www.idahoelderlaw.com.

Tim A. Tarter, Of Counsel

Tim Tarter has over 25 years of experience representing clients in all aspects of federal, state, and international tax controversy matters, including IRS audits and appeals as well as trial and appellate litigation. Calling on his experience as a former IRS senior attorney, Tim frequently resolves tax disputes prior to trial on favorable terms for the client. If needed, however, Tim has substantial experience litigating tax disputes in the U.S. Tax Court and other federal courts. Tim was born and raised in Idaho, but spends most of his time in Phoenix to keep his golf handicap lower than Darin's.

Education:

J.D., Willamette University College of Law (1986)
B.S., Finance/Accounting, Oregon State University (1983)

Professional Recognition:

Super Lawyer, Mountain States 2013

Professional Memberships and Civic Activities:

ABA Section of Taxation
United Way Finance Committee

Bar and Court Admissions:

Idaho
Arizona
Oregon (inactive)
United States Tax Court
U.S. Court of Federal Claims

William J. Whitaker

Bill Whitaker is an associate attorney in the Boise office of Ahrens DeAngeli Law Group and helps clients accomplish their wealth preservation, business succession and charitable goals with tailored estate plans. Bill also assists clients with trust and estate administration and related tax issues. Bill joined ADLG in 2009 after law school and has previously worked as a law clerk for the Utah Attorney General and other law firms. He was also a judicial extern for the Utah State Tax Commission and the Honorable B. Ted Stewart of the United States District Court. After years of practicing with ADLG, Bill is finally able to correctly pronounce the name of the firm.

Education:

Master of Laws (LL.M.) taxation, New York University (2009)
J.D., University of Utah S.J. Quinney College of Law, with honors; Utah Law Review; Journal of Law & Family Studies; Jackie Chiles Law Society, founding board member (2008)
B.S., Finance, Brigham Young University (2004)

Professional and Civic Memberships:

Ronald McDonald House Charities of Idaho, planned giving and gift acceptance committee member
Southwest Idaho Planned Giving Council, member
J. Reuben Clark Law Society, member

Bar and Court Admissions:

Idaho
Utah

David J. Wilson

David Wilson joined Ahrens DeAngeli Law Group in 2011 after two years with a boutique estate planning and probate litigation firm in Phoenix, Arizona. He graduated cum laude from the Arizona State University Sandra Day O’Connor College of Law before completing a Master of Laws degree in taxation at the New York University School of Law, where he was one of the top students. David also spent a year clerking for the Honorable Daniel Barker of the Arizona Court of Appeals. While in law school, David completed externships for the Honorable Roslyn Silver of the United States District Court and the United States Attorney’s Office for the District of Arizona. David never used to have a sense of humor, but years of reading the tax code has given him a new ability to laugh at the absurd.

Education:

Master of Laws (LL.M.) taxation, New York University (2009)
J.D., Arizona State University Sandra Day O'Connor College of Law, cum laude; Arizona State Law Journal (2007)
B.S., Computer Science, Brigham Young University (2004)

Professional and Civic Memberships:

Southwest Idaho Planned Giving Council, board member

Bar and Court Admissions:

Arizona
Idaho

Ahrens DeAngeli Creates Elder Law Group

Ahrens DeAngeli Law Group is pleased to announce our merger with Sisson & Sisson, The Elder Law Firm, to create the Elder Law Group at Ahrens DeAngeli Law Group. With this merger, Ahrens DeAngeli Law Group is now the largest and most experienced Elder Law firm in Idaho.

Peter C. Sisson, former principal of Sisson & Sisson, The Elder Law Firm, will head this practice area. His practice emphasizes a comprehensive approach to the issues seniors face as they age—anticipating and providing legal services as their circumstances and health care needs change. Pete is a board-certified elder law attorney and board-certified estate planning law specialist.

Please contact Ahrens DeAngeli Law Group at (208) 639-7799 or visit www.idahoelderlaw.com to learn more about Peter and our elder law service offerings.

Ahrens DeAngeli Recognized for Practice Excellence

Ahrens DeAngeli was named the 2013 Boutique Trust & Estate Law Firm of the Year in Washington by Corporate INTL Magazine. The Corporate INTL Legal Awards are based on comprehensive and detailed research focusing on expertise, service range, business type, and geographical location. In its fifth consecutive year, the Legal Awards program is one of the largest and most well respected of its kind.

American Taxpayer Relief Act of 2012

The recently enacted American Taxpayer Relief Act of 2012 (ATRA) provides significant opportunities to engage in meaningful tax planning for large estates, much like the tax law of recent years. The gift, estate and generation-skipping transfer (GST) tax exemption amounts have increased in 2013, together with the top tax rates. Among other things, ATRA specifically provides:

  • $5,250,000 of gift, estate and GST tax exemption per person ($10,500,000 per couple, indexed for inflation in subsequent years);
  • a top tax rate of 40% (up from 35% in 2012);
  • a gift tax annual exclusion amount of $14,000 per year per person (indexed for inflation in subsequent years); and
  • portability rules allowing a surviving spouse to use his or her deceased spouse’s remaining gift and estate tax exemption amount (during the surviving spouse’s life or at his or her death).
Unlike the tax law of recent years, these and most other ATRA provisions are not scheduled to sunset (i.e., they are "permanent"). However, it is possible that even some "permanent" provisions of ATRA may change as early as this year as part of comprehensive tax reform and deficit reduction legislation. Because of this possibility, and because of the favorable tax laws and unprecedented low interest rates (see Applicable Federal Rates), anyone contemplating a transfer of property should consider making the transfer soon.

Please contact one of our attorneys if you would like to learn more about ATRA, wealth transfer or any other issues relating to tax, estate and/or charitable planning. We can be reached in our Boise office at 208-639-7799 and in our Seattle office at 206-652-0101.

IRS CIRCULAR 230 DISCLOSURE:
To ensure compliance with requirements imposed by the U.S. Internal Revenue Service, we inform you that any tax advice contained in this communication (including any attachments) was not intended or written to be used, and cannot be used, by any taxpayer for the purpose of (1) avoiding tax-related penalties under the U.S. Internal Revenue Code, or (2) promoting, marketing or recommending to another party any tax related matters addressed herein.