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IRC Section 199A and 643(f) Proposed Treasury Regs: A Detailed Look at the Separate Trust Rules to Maximize the 20% Pass-Thru Business Deduction



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The last few pages of the recent IRC Section 199A and 643(f) Proposed Treasury Regulations are arguably the most important for estate planners who are looking for ways to exploit and maximize the new 20% pass-thru business deduction.  IRC Section 643(f) restricts the number of separate $157,500 income thresholds that can obtain the 20% deduction using multiple non-grantor trusts.  But the Proposed Regulations only provide two examples.  Join nationally-known estate planning attorney Steve Oshins as he goes through the details of these two examples and also supplements this with details of the evolution of Section 643(f), including the Committee Reports from 1984, including the examples from those Reports, and Private Letter Rulings interpreting these rules.  Whether you’re an attorney, an accountant, a trust officer or a financial planner, it is crucial for you to attend this very important webinar.  In total, you will have 90 minutes of exciting, informative discussion.   Join Steve Oshins on August 31st at 3pm ET when he will give you a step-by-step tutorial to help you know exactly how to plan around these limitations.

 In this webinar, you will: 

  • Get a summary of the 20% pass-thru business deduction

  • Learn the rules for a Specified Service Business

  • Learn the rules for a non-Specified Service Business

  • Explore exactly how IRC Section 643(f) works

  • Go through the history behind Section 643(f), including case law

  • Learn about the 1984 Committee Reports, including the two examples provided therein

  • Get examples illustrating what can and cannot be done

  • Discover which Private Letter Rulings interpreted Section 643(f) and what they ruled

  • Find out who can be beneficiaries of separate trusts without violating these new rules

  • Learn how to include the settlor’s spouse as a beneficiary and still make it a non-grantor trust

  • Hear about how the settlor can be a beneficiary of a completed gift non-grantor trust to increase the 20% deduction

  • Explore the use of a NING Trust and how that can be used, even for a non-state income tax reason

  • And much more!


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Steven J. Oshins, Esq., AEP (Distinguished) is a member of the Law Offices of Oshins & Associates, LLC in Las Vegas, Nevada. He is listed in The Best Lawyers in America® and was named the Las Vegas Trusts and Estates Lawyer of the Year in 2012 and 2015 and the Las Vegas Tax Law Lawyer of the Year in 2016 by The Best Lawyers in America®. He was inducted into the NAEPC Estate Planning Hall of Fame® in 2011. He is rated AV by the Martindale-Hubbell Law Directory. He has been named one of the 24 ""Elite Estate Planning Attorneys"" in America by The Trust Advisor, one of the Top 100 Attorneys in Worth, one of Southern Nevada's Best Lawyers in In Business Las Vegas, one of the Best Lawyers in America in the Trusts & Estates category in The American Lawyer, one of the Best Lawyers in America in the Tax Law category in Corporate Counsel, named Nevada Super Lawyer in the Wills, Trusts & Estate Planning category in Nevada Business Journal, named Nevada Super Lawyer in the Estate Planning & Probate category in Las Vegas Life and named Mountain States Super Lawyer in the Estate Planning & Probate category. He was also named one of Southern Nevada's Top Lawyers by Vegas, Inc. and was selected for the magazine cover.


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