Maximizing excess deductions on termination.Tax savings can be optimized if the executor executor n. the person appointed to administer the estate of a person who has died leaving a will which nominates that person. Unless there is a valid objection, the judge will appoint the person named in the will to be executor. (or trustee), CPA (Computer Press Association, Landing, NJ) An earlier membership organization founded in 1983 that promoted excellence in computer journalism. Its annual awards honored outstanding examples in print, broadcast and electronic media. The CPA disbanded in 2000. and attorney work together to plan when to pay an estate's or trust's expenses, close the entity and take deductions in the termination year. Through the use of a comprehensive example, this article explains how to maximize the tax benefits available in the final year of an estate or trust. If an estate or trust has a loss in its final year, it can (with some adjustments discussed below) be passed through to the beneficiaries, allowing them a deduction deduction, in logic, form of inference such that the conclusion must be true if the premises are true. For example, if we know that all men have two legs and that John is a man, it is then logical to deduce that John has two legs. on their returns. Losses in a nontermination year cannot be passed through to beneficiaries. To the extent a loss is comprised of nonbusiness non·busi·ness adj. 1. Unrelated to business or industry. 2. Unrelated to one's own business or employment. deductions, the entity cannot carry it back or forward (only business deductions Noun 1. business deduction - tax write-off for expenses of doing business entertainment deduction - deduction allowed for some (limited) kinds of entertainment for business purposes , as defined by Sec. 172(d)(4), can be carried to other years, as part of a net operating loss operating loss The excess of operating expenses over revenue. As with operating income, operating losses exclude revenues and expenses from operations that are not considered a regular part of the business. Also called deficit. Compare operating income. (NOL NOL - Never Offline )). Thus, an estate's or trust's loss comprised of nonbusiness deductions will be lost as a tax benefit by either the entity or its beneficiaries, unless incurred in the entity's termination year. Accordingly, some thought should be given to the tinting tint n. 1. A shade of a color, especially a pale or delicate variation. 2. A gradation of a color made by adding white to it to lessen its saturation. 3. A slight coloration; a tinge. 4. of nonbusiness deductions toward the end of the estate's or trust's existence. Further, consideration of other factors (including the creation of a short final year for the entity) may greatly increase the tax benefits available to the beneficiaries. The tax benefits available by distributing the excess deductions on termination (EDOTs) in the final year can be maximized by: * Understanding the concept and mechanics of computing computing - computer the EDOT EDOT Essential Dimensions of Teaching EDOT Episcopal Diocese of Texas deduction. * Comprehending the factors contributing to the amount and timing of EDOTs over which the executor or trustee has control (including an analysis of when to end the entity's final year). * Communication and teamwork (product, software, tool) Teamwork - A SASD tool from Sterling Software, formerly CADRE Technologies, which supports the Shlaer/Mellor Object-Oriented method and the Yourdon-DeMarco, Hatley-Pirbhai, Constantine and Buhr notations. between the CPA, attorney and executor or trustee to allow such planning to take place. This article explores how the beneficiaries' tax benefits can be maximized if the executor or trustee and the professionals involved in the administration of an estate or trust engage in proper planning. What Is an EDOT? The taxation of beneficiaries and the corresponding distribution deduction of trusts and estates are addressed in Secs. 651 and 652 (for simple trusts) and Secs. 661 and 662 (for estates and complex trusts). These sections provide the methods for determining a beneficiary's income from an estate or trust and the entity's distribution deduction, but do not provide a method for passing through losses. Were it not for other sections providing special rules, an entity's loss would never result in a tax benefit to beneficiaries. The following sections allow deductions and losses to be passed through to beneficiaries: 1. Secs. 642(e), 167(d) and 611(b), which provide for an allocation The apportionment or designation of an item for a specific purpose or to a particular place. In the law of trusts, the allocation of cash dividends earned by a stock that makes up the principal of a trust for a beneficiary usually means that the dividends will be treated as of depreciation and depletion depletion n. when a natural resource (particularly oil) is being used up. The annual amount of depletion may, ironically, provide a tax deduction for the company exploiting the resource because if the resource they are exploiting runs out, they will no longer be able deductions to beneficiaries. 2. Sec. 691 (c), which allows the recipient of income in respect of a decedent An individual who has died. The term literally means "one who is dying," but it is commonly used in the law to denote one who has died, particularly someone who has recently passed away. a deduction for the Federal estate tax attributable attributable emanating from or pertaining to attribute. attributable proportion see attributable risk (below). attributable risk to that item. 3. Sec. 642(h)(1), which allows beneficiaries the entity's unused capital losses and NOLs in the termination year only. 4. Sec. 642(h)(2), which allows deductions to beneficiaries if the entity's deductions exceed its gross income (i.e., if it has EDOTs) in the termination year only. Thus, #1 and #2 above allow special deductions to be allocated to beneficiaries, while #3 and #4 above provide an opportunity for beneficiaries to capture tax benefits from an estate's or trust's tax loss; this article focuses on #4. Sec. 642(h) provides that, if on termination of an estate or trust, (1) it has a Sec. 172 NOL carryover carryover n. in taxation accounting, using a tax year's deductions, business losses or credits to apply to the following year's tax return to reduce the tax liability. (See: carryback) or a Sec. 1212 capital loss carryover (CLC (The Computer Language Company Inc.) The publisher of this Encyclopedia. See About this product. ) or (2) for its last tax year, it has deductions (other than the personal exemption Personal exemption Amount of money a taxpayer can exclude from personal income for each member of the household in calculation of a tax obligation. personal exemption See exemption. or charitable deductions) in excess of termination year gross income, the carryover or excess is allowed as a deduction to the entity's beneficiaries, as prescribed pre·scribe v. pre·scribed, pre·scrib·ing, pre·scribes v.tr. 1. To set down as a rule or guide; enjoin. See Synonyms at dictate. 2. To order the use of (a medicine or other treatment). by regulations. While this appears to be straightforward, what if an NOL and/or and/or conj. Used to indicate that either or both of the items connected by it are involved. Usage Note: And/or is widely used in legal and business writing. CLC is also available in the termination year? Regs. Sec. 1.642(h)-2(c) provides that any item of income or deduction (or any part thereof) taken into account in determining the entity's NOL or CLC for its last tax is not taken into account again in determining the entity's EDOTs. Thus, the EDOT computation Computation is a general term for any type of information processing that can be represented mathematically. This includes phenomena ranging from simple calculations to human thinking. is as follows: Taxable loss (Form 1041, U.S. Income Tax Return for Estates And Trusts, Line 22) $X Reduced by the following items included in loss: Personal exemption (X) Charitable deduction (X) NOL (X) CLC (X) EDOT $X Because the passthroughs allowed by Sec. 642(h) are allowed only in the termination year, any net taxable losses in a nontermination year that are not part of an NOL or CLC will not be available to reduce the entity's or the beneficiaries' taxable income Under the federal tax law, gross income reduced by adjustments and allowable deductions. It is the income against which tax rates are applied to compute an individual or entity's tax liability. The essence of taxable income is the accrual of some gain, profit, or benefit to a taxpayer. . To increase EDOTs, nonbusiness deductions should be incurred in the year of termination; otherwise, they could be forever lost as a tax benefit. (This presumes a tax loss would exist in the year of termination, including the nonbusiness deductions.) EDOTs are miscellaneous itemized deductions Itemized Deduction A deduction from a taxpayer's taxable adjusted gross income that is made up of deductions for money spent on certain goods and services throughout the year. subject to the Sec. 67 2% adjusted gross income (AGI (Artificial General Intelligence) A machine intelligence that resembles that of a human being. Considered impossible by many, most artificial intelligence (AI) research, projects and products deal with specific applications such as industrial robots, playing chess, ) floor and are to be added back to taxable income in computing alternative minimum taxable income, an adjustment that may result in an alternative minimum tax (AMT See vPro. ) liability. AMT may reduce some of the regular tax benefits of an EDOT. EDOT Planning Under Regs. Sec. 1.641(b)-3(a), an estate's period of administration or settlement is the period actually required by the administrator or executor to collect assets and pay debts, taxes and bequests, whether that period is longer or shorter than the period specified by state law. The executor (or trustee, in the case of a trust) and the attorney generally have a fair amount of control over when this period ends. If a timing decision would increase the EDOT available to beneficiaries, it most likely is within the fiduciary's control to implement it. Because the timing of deductions for a cash-basis estate or trust is controlled by the payment of the entity's bills, the executor or trustee has flexibility in determining the year of deductions. Special attention should be focused on the nonbusiness deductions, because they are more likely to be lost in the absence of EDOT planning. Often, the most significant nonbusiness deductions will be the attorney's CERTIFICATE, ATTORNEY'S, Practice, English law. By statute 37 Geo. III., c. 90, s. 26, 28, attorneys are required to deliver to the commissioners of stamp duties, a paper or note in writing, containing the name and usual place of residence of such person, and thereupon, on paying certain , accountant's and executor's fees. This is the team that should be working together to maximize the tax benefits for the entity and its beneficiaries. Consideration should also be given to the tax effect of distributions to beneficiaries in the entity's termination year. Coordinating distribution planning with EDOT planning in the final year can result in significant savings. Factors to Consider The comprehensive illustration below demonstrates how controlling the final year-end year-end also year·end n. The end of a year. adj. Occurring or done at the end of the year: a year-end audit. Noun 1. and the timing of deductions for an estate or trust, coupled with distribution planning, affect the entity's and the beneficiaries' taxes. However, there are additional factors (not reflected m the illustration) that can also be useful EDOT planning tools in certain cases; some of these factors are: Investment selection: The deductions that would result in an EDOT are generally required to be allocated between taxable and tax-exempt income Tax-exempt income Dividends and interest not subject to federal and, in some cases, state and local income taxes. . Deductions allocated to tax-exempt income are disallowed; hence, they do not increase EDOTs. This loss of deductions can be reduced by avoiding investment in tax-exempt tax-ex·empt adj. 1. Not subject to taxation, as the capital or income of a philanthropic organization. 2. Producing interest that is exempt from income tax: tax-exempt bonds. n. assets. Sale of assets: If assets are sold at a gain in the entity's final year, the increase in income will reduce (or eliminate) the potential EDOT. The alternative of distributing the assets to beneficiaries should be considered. In some cases, the beneficiaries might prefer the assets, especially considering the potential income tax advantage. Waiving executor's fees: Consider waiving executor's fees when the executor is the sole (or primary) estate beneficiary beneficiary Person or entity (e.g., a charity or estate) that receives a benefit from something (e.g., a trust, life-insurance policy, or contract). A primary beneficiary receives proceeds from a trust or insurance policy before any other. . This strategy may at first seem counter-intuitive A counter-intuitive proposition is one that does not seem likely to be true when assessed using intuition or gut feelings. Scientifically discovered, objective truths are often called counter-intuitive , as waiving the fees will reduce or eliminate the EDOT. However, when the executor/beneficiary is the recipient of the entire estate, it is a mistake to create income for him (by taking a taxable fee) when he could receive the estate tax-free tax-free adj. Not subject to taxation; tax-exempt. tax-free Adjective not needing to have tax paid on it: a tax-free lump sum Adj. 1. by inheritance inheritance, in law inheritance, in law: see heir. inheritance, in biology inheritance, in biology: see heredity. inheritance Devolution of property on an heir or heirs upon the death of its owner. . Only under unusual conditions would such an executor/beneficiary fully offset his taxable fees by the EDOT deduction (which is subject to the 2% AGI threshold). Creating an unnecessary EDOT: In certain cases, creating an EDOT will not aid the beneficiaries, e.g., when the (1) EDOT plus other miscellaneous itemized deductions do not exceed the 2% AGI floor or (2) total itemized deductions (including the EDOT) do not exceed the beneficiary's standard deduction The name given to a fixed amount of money that may be subtracted from the adjusted gross income of a taxpayer who does not itemize certain living expenses for Income Tax purposes. . Comprehensive Illustration What effect does EDOT planning have on the income tax of an estate and its beneficiaries? The following facts are common to the four examples below. Facts J died on Dec. 21, 1996. She was a widow widow n. a woman whose husband died while she was married to him and has not since remarried. A divorced woman whose ex-husband dies is not a widow, except for the purpose of certain Social Security benefits traceable to the ex-husband. WIDOW. who died intestate The description of a person who dies without making a valid will or the reference made to this condition. intestate adj. referring to a situation where a person dies without leaving a valid will. . Her heirs are her son, A, and her daughters, B and C.J's net taxable estate Taxable Estate The total value of a deceased person's assets that are subject to taxation - minus liabilities and minus the prescribed tax-deductible portion of assets left behind by the deceased. is $600,000; the estate's year ends on November November: see month. 30. As of Nov. 10, 1997, the following estate expenses were still outstanding: Attorney's fee $30,000 CPA's fee 15,000 Executor's fee 25,000 Total $70,000 Year-to-date taxable income: Capital gain $20,000 All else (net) $16,000 Projected fees to complete probate: Attorney $ 5,000 CPA 1,000 Executor 3,000 Total $ 9,000 Future taxable income is $1,000/month Probate probate (prō`bāt), in law, the certification by a court that a will is valid. Probate, which is governed by various statutes in the several states of the United States, is required before the will can take effect. could be completed by Nov. 30, 1997 In addition, for each of 1997 and 1998, A, B and C each are calendar-year taxpayers married filing jointly Married Filing Jointly A filing status for married couples that have wed before the end of the tax year. They can record their respective incomes, exemptions and deductions on the same tax return. Married filing jointly is best if only one spouse has a significant income. , itemize To individually state each item or article. Frequently used in tax accounting, an itemized account or claim separately lists amounts that add up to the final sum of the total account on claim. , and have anticipated taxable income (before estate items) of $85,000; further, their miscellaneous itemized deductions (before EDOTs) exceed the 2% AGI floor. In Examples 1-4 below, the estate's personal exemption has been ignored; all capital gains are taxed at 28%; and, for AMT purposes, the only tax preference items are a $3,500 real estate tax deduction Tax deduction An expense that a taxpayer is allowed to deduct from taxable income. tax deduction See deduction. and the 2% miscellaneous itemized deductions (which include the EDOT). Example 1: The executor pays the professional fees due by the Nov. 30, 1997 yearend. The final distributions and settling of the estate are not accomplished until February February: see month. 1998. The total tax saving to the beneficiaries (occurring in 1998) is $1,680; see the table on pages 476-477.
J's Estate(*)
Amount Income/
(deduction)
Example 1:
Estate (FYE 11/30/97):
Taxable to 11/10/97, $20,000
Capital gain
Taxable to 11/10/97, 16,000
All else
11/10/97-11/30/97, Pro 667
rate earnings
11/10/97-11/30/97, (70,000) $(33,333)
Fees deduction
Estate (FYE 2/28/98 (Final)):
Taxable 12/1/97-2/28/98,
Pro rate earnings $3,000
12/1/97-2/28/98, (9,000) $(6,000)
Fees deduction
Beneficiaries, 1997 K-1:
A $0
B $0
C $0
Beneficiaries, 1998 K-1:
A (share of EDOT) $(2,000)
B (share of EDOT) $(2,000)
C(share of EDOT) $(2,000)
Total (estate and
beneficiaries)
Example 2:
Estate (FYE 11/30/97):
Taxable to 11/10/97, $20,000
Capital gain
Taxable to 11/10/97,
All else 16,000
11/10/97-11/30/97, 667
Pro rate earnings
11/10/97-11/30/97, 0 $63,667
Fees deduction
Estate (FYE 12/31/97 (Final)):
Taxable 12/1/97-12/31/97,
Pro rate earnings $1,000
12/1/97-12/31/97, (79,000) $(78,000)
Fees deduction
Beneficiaries, 1997 K-1
(Estate FYE11/30/97):
A $0
B $0
C $0
Beneficiaries, 1997 K-1
(Estate FYE 12/31/97):
A $(26,000)
B S(26,000)
C S(26,000)
Total (estate and
beneficiaries)
Example 3:
Estate (FYE 11/30/97):
Taxable to 11/10/97, $20,000
Capital gain
Taxable to 11/10/97, 16,000
All else
11/10/97-11/30/97, Pro 667
rate earnings
11/10/97-11/30/97, 0
Fees deduction
Distribution deduction (16,667) $20,000
Estate (FYE 12/31/97 (Final)):
Taxable 12/1/97-12/31/97,
Pro rate earnings $1,000
12/1/97-12/31/97, (79,000) $(78,000)
Fees deduction
Beneficiaries, 1997 K-1
(Estate FYE 11/30/97):
A $5,556
B $5,556
C $5,556
Beneficiaries, 1997 K-1
(Estate FYE 12/31/97):
A $(26,000)
B $(26,000)
C $(26,000)
Total (estate and
beneficiaries)
Example 4:
Estate (FYE11/30/97 (Final)):
Taxable to 11/10/97, $20,000
Capital gain
Taxable to 11/10/97, 16,000
All else
11/10/97-11/30/97, Pro 667
rate earnings
11/10/97-11/30/97, (79,000)
Fees deduction
Distribution deduction 0 $(42,333)
Beneficiaries, 1997 K-1
(Estate FYE 11/30/97):
A (share of EDOT) $(14,111)
B (share of EDOT) $(14,111)
C(share of EDOT) $(14,111)
Total (estate and
beneficiaries)
Tax increase/
(decrease) Comments
Example 1:
Estate (FYE 11/30/97):
Taxable to 11/10/97,
Capital gain
Taxable to 11/10/97,
All else
11/10/97-11/30/97,
Pro rate earnings
11/10/97-11/30/97, $0 No EDOT
Fees deduction
Estate (FYE 2/28/98 (Final)):
Taxable 12/1/97-2/28/98,
Pro rate earnings
12/1/97-2/28/98, 0 EDOT (final year)
Fees deduction
Beneficiaries, 1997 K-1:
A $0
B $0
C $0
Beneficiaries, 1998 K-1:
A (share of EDOT) $(560)
B (share of EDOT) (560)
C(share of EDOT) (560)
Total (estate and $(1,680)
beneficiaries)
Example 2:
Estate (FYE 11/30/97):
Taxable to 11/10/97,
Capital gain
Taxable to 11/10/97,
All else
11/10/97-11/30/97,
Pro rate earnings
11/10/97-11/30/97,
Fees deduction $11,304 No EDOT or
distributions
Estate (FYE 12/31/97 (Final)):
Taxable 12/1/97-12/31/97,
Pro rate earnings
12/1/97-12/31/97, $0 EDOT (final year)
Fees deduction
Beneficiaries, 1997 K-1
(Estate FYE11/30/97):
A $0
B $0
C $0
Beneficiaries, 1997 K-1
(Estate FYE 12/31/97):
A $(5,763) $1,517 AMT
B (5,763) $1,517 AMT
C (5,763) $l,517 AMT
Total (estate and $(5,985)
beneficiaries)
Example 3:
Estate (FYE 11/30/97):
Taxable to 11/10/97,
Capital gain
Taxable to 11/10/97,
All else
11/10/97-11/30/97,
Pro rate earnings
11/10/97-11/30/97,
Fees deduction
Distribution deduction $5,392 No EDOT
Estate (FYE 12/31/97 (Final)):
Taxable 12/1/97-12/31/97,
Pro rate earnings
12/1/97-12/31/97, $0 EDOT (final year)
Fees deduction
Beneficiaries, 1997 K-1
(Estate FYE 11/30/97):
A 1,556
B 1,556
C 1,556
Beneficiaries, 1997 K-1
(Estate FYE 12/31/97):
A $(5,763) $1,517 AMT
B (5,763) $1,517 AMT
C (5,763) $1,517 AMT
Total (estate and $(7,230)
beneficiaries)
Example 4:
Estate (FYE11/30/97 (Final)):
Taxable to 11/10/97,
Capital gain
Taxable to 11/10/97,
All else
11/10/97-11/30/97,
Pro rate earnings
11/10/97-11/30/97,
Fees deduction
Distribution deduction $0 EDOT,
distributions
Beneficiaries, 1997 K-1
(Estate FYE 11/30/97):
A (share of EDOT) $(3,962) No AMT
B (share of EDOT) (3,962) No AMT
C(share of EDOT) (3,962) No AMT
Total (estate and $(11,886)
beneficiaries)
(*) Rounding errors Noun 1. rounding error - (mathematics) a miscalculation that results from rounding off numbers to a convenient number of decimals; "the error in the calculation was attributable to rounding"; "taxes are rounded off to the nearest dollar but the rounding error is have been ignored. In this example, there are "lost" deductions for the fiscal year ended Nov. 30, 1997; these are nonbusiness deductions that cannot be carried forward (or back) to offset any other year's taxable income. Further, because these deductions fall in the year before estate termination, they will never be allowed to the beneficiaries. Finally, although the estate's final return reflects a $6,000 EDOT, the beneficiaries do not realize their tax benefits until 1998. Example 2: Here, the professional fees outstanding on Nov. 10, 1997 are paid in December December: see month. 1997, thus putting the deduction into the next fiscal year. Also, the administration of the estate is accelerated; the process is completed (and the final year ended) Dec. 31, 1997. This situation results in the creation of an EDOT. The result for the estate and beneficiaries is a net tax savings of $5,985, a $4,305 increase over Example 1; see the table on pages 476-477. Although the estate has a tax liability for fiscal year-end Fiscal Year-End The completion of a one-year, or 12-month, accounting period. Notes: The reason that a company's fiscal year often differs from the calendar year and does not close on Dec 31, is due to the nature of company's needs. Nov. 30, 1997, this is more than made up for in total tax savings by the EDOT resulting from the fees deduction in the final year. The $78,000 EDOT provides a significant improvement over the "lost" deduction problem in Example 1. Although the beneficiaries' 28% tax rate applies to their individual $26,000 EDOT, resulting in a regular tax savings of $7,280, the itemized deduction causes each a $1,517 AMT liability. Because of the estate's Dec. 31, 1997 final year-end, the beneficiaries realize the tax benefits in the 1997 tax year. Example 3: Here, the professional fees are paid in the final year, and distributions to beneficiaries of $100,000 are made before the Nov. 30, 1997 year-end. This shifts taxable income from the higher-bracket estate to the lower-bracket beneficiaries, increasing the tax savings by $5,550 over Example 1; see the table on pages 476-477. Although the estate will have to pay tax for the Nov. 30, 1997 year-end based on the capital gains recognized in that nontermination year, the income shift to the beneficiaries is an improvement over the results in Example 2. Because the estate's Nov. 30, 1997 yearend and its final year-end fall within the same calendar year of the beneficiaries, the EDOT (for year-end Dec. 31, 1997) offsets the beneficiaries' potential tax liability for the 1997 tax year. As in Example 2, the EDOT results in a $1,517 AMT liability for each beneficiary, thus reducing the tax benefits of the EDOT. Example 4: Here, the tax savings are maximized. Estate administration is completed and all bills are paid before the Nov. 30, 1997 year-end, making this the estate's final year. The tax savings increase by $10,206 over Example 1; see the table on pages 476-477. No AMT results from each beneficiary's $14,111 EDOT. Deducting Administration Expenses The above examples reflect situations in which administrative expenses are taken as income tax deductions (as opposed to estate tax deductions) . This is the optimal approach for these scenarios, because such deductions (on the estate's Form 706, U.S. Estate (and Generation-Skipping Transfer) Tax Return) would otherwise have been wasted in J's nontaxable adj. 1. Not subject to taxation; - of goods imported into a country or sold at retail outlets; as, most laws imposing sales taxes make food nontaxable s>. Opposite of taxable nt>. Adj. 1. estate. The analysis and decision as to which return should reflect the deduction for administrative expenses--i.e., Form 706 or 1041--is necessarily made early in the entity's existence. To take administrative expenses as an estate income tax deduction, an irrevocable Unable to cancel or recall; that which is unalterable or irreversible. IRREVOCABLE. That which cannot be revoked. 2. A will may at all times be revoked by the same person who made it, he having a disposing mind; but the moment the testator is election under Regs. Sec. 1.642(g)-1 must be filed to waive To intentionally or voluntarily relinquish a known right or engage in conduct warranting an inference that a right has been surrendered. For example, an individual is said to waive the right to bring a tort action when he or she renounces the remedy provided by law for such the expenses as an estate tax deduction. Conclusion Although real-world situations are often more complex than was presented here, when the professionals (CPA and attorney) work together with the executor or trustee as a team, real tax savings can occur. Knowledge of this area can be useful in attracting new business. One effective technique is to send letters in the beginning of the process to the executor (or trustee), beneficiaries and other professionals on the team outlining the potential for tax savings. This should be followed up at the end of the process with correspondence quantifying the savings that resulted from everyone's efforts. RELATED ARTICLE: EXECUTIVE SUMMARY * The estate's or trust's executor or trustee, CPA and attorney should work together to maximize tax benefits for the entity and the beneficiaries. * AMT may reduce some of the regular tax benefits of EDOTs. * Coordinating distribution planning with EDOT planning in the final year can result in significant tax savings. |
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