On June 6, 2024, the Supreme Court released its much anticipated decision in the Estate of Connelly v. United States, No. 23-146, (U.S. June 6 2024). The Court ruled in favor of the IRS and held that a corporation's obligation to redeem a deceased shareholder's ownership interest - under a stock redemption agreement - does not offset any includable corporate-owned life insurance proceeds when calculating the value of the corporation for estate tax purposes. This overturns the longstanding ruling by the 11th Circuit in Estate of Blount v. Commissioner, 428 F. 3d. 1338 (11th Cir. 2005). This presentation will cover key issues including:
Understanding the Court's rationale in overturning Estate of Blount v Commissioner.
What does the decision mean to entity redemption buy-sell agreements moving forward?
How best to effectively plan moving forward to ensure tax efficiency and effectiveness.