OBBBA and NonGrantor Trust Planning: QBI, QSSB and SALT

The One Big Beautiful Bill Act (OBBBA) has changed income tax planning in many ways. Several of these beneficial tax changes are the enhanced deductions for Qualified Business Income (QBI) under Code Sec. 199A, the exclusion for certain gains on Qualified Small Business Stock (QSBS) under Code Sec. 1202, and the enhanced State and Local Tax (SALT) deduction. Each of these tax benefits, and how OBBBA enhanced them will be explained and each will be followed by a practical discussion of how taxpayers may be able to use non-grantor trusts to either qualify for these benefits, multiply the potential benefits, and/or avoid income limitations that absent this planning would be phased out and reduced or obviated for a particular taxpayer. Basic background information on how non-grantor trusts work, how they can be applied in each of the above post-OBBBA income tax planning scenarios, special considerations of state income taxation of non-grantor trusts, the limitation on using multiple trusts under Code Sec. 643(f), and more will all be presented. Speakers: Christine Pronek, Lauren Landolfi, Len Nitti, all CPAs with WilkinGuttenplan, and Martin Shenkman, Esq.