Swap Power and the Step-Up in Basis: Do You Need One If Your Assets Never Left Your Estate?
A CPA who advises ultra-high-net-worth families left a sharp question on one of my posts last week. I had written…
Does an Offshore Trust Preserve the Step-Up in Basis?
Does an Offshore Trust Preserve the Step-Up in Basis? Rev. Rul. 2023-2 says completed gifts to a grantor trust get no §1014 step-up. Most offshore trusts are completed gifts. What that costs, and the design question that decides it.