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D.C. Estate Tax Exemption Will Increase . . . but When?

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D.C. Estate Tax Exemption Will Increase . . . but When? CLIENT ALERT MCARTHUR FRANKLIN PLLC (MARCH 4, 2015) D.C. Estate Tax Exemption Will Increase . But When? The presumably permanent federal estate tax exemption of $5,000,000, as indexed for inflation, has created an increased focus on state estate taxes. In order to remain attractive to individuals concerned about estate tax exposure, some states have recently passed legislation to increase their estate tax exemptions.1 For example, Maryland enacted a new law that gradually increases the Maryland estate tax exemption each year until it matches the federal estate tax exemption in 2019. The District of Columbia recently enacted the Tax Revision Commission Implementation Amendment Act of 2014 (the “TRC Act”), which became law on February 26, 2015, and makes several changes to the D.C. estate tax law. I. Current D.C. Estate Tax Law. The District of Columbia imposes a local estate tax on: (i) the taxable estate of its residents; and (ii) the D.C. situs assets (i.e., real estate and tangible personal property) of non-residents. The current D.C. estate tax exemption is $1,000,000, which has not increased since 2003. As a result, a D.C. resident or a non-resident decedent who owns D.C. situs property with a gross estate in excess of $1,000,000 will be required to file a D.C. estate tax return. The current D.C. estate tax uses a graduated tax rate with 21 tax brackets that range from 0% for adjusted taxable estates under $40,000 to 16% for amounts over $10,400,000. II. New D.C. Estate Tax Legislation. The TRC Act makes numerous changes to D.C.’s tax laws, including a couple of significant changes to the estate tax law. A. Increased D.C. Exemption Amount. The D.C. estate tax exemption will increase to $2,000,000 as early as 2016, and then later increase to $5,000,000 (including adjustments for inflation). The D.C. estate tax exemption is referred to under the new estate tax law as the “zero bracket amount.” Unfortunately, the promise of an increased D.C. estate tax exemption is subject to the District of Columbia’s ability to raise sufficient revenue to support such a “tax cut.” The TRC Act provides a list of 17 tax reforms that will be phased in to the D.C. tax system when there is sufficient revenue to support such tax cuts. The increase of the D.C. estate tax exemption from $1,000,000 to $2,000,000 is the 6th tax reform in the list; the increase of the D.C. estate tax exemption to $5,000,000 (as adjusted for inflation) is the 13th tax reform in the list. B. Modified D.C. Estate Tax Rates. Under the TRC Act, the amount of the D.C. estate tax for decedents dying in 2016 or later years is 16%, with lower tax rates applied to certain incremental values of the taxable estate if the estate exceeds the D.C. exemption amount. The incremental tax rates set forth in the TRC Act are as follows: 1 Virginia repealed its estate tax effective July 1, 2007. Copyright 2015 McArthur Franklin PLLC Page 1 All Rights Reserved. Value of Taxable Estate Tax Rate Over But not Over $2,000,000 $2,500,000 8.0% $2,500,000 $3,000,000 8.8% $3,000,000 $3,500,000 9.6% $3,500,000 $4,000,000 10.4% $4,000,000 $5,000,000 11.2% $5,000,000 $6,000,000 12.0% $6,000,000 $7,000,000 12.8% $7,000,000 $8,000,000 13.6% $8,000,000 $9,000,000 14.4% $9,000,000 $10,000,000 15.2% $10,000,000 16.0% The new D.C. estate tax rates become effective in 2016, even if the exemption amount does not increase in 2016 because of insufficient revenue. Notably absent is the tax rate for amounts between $1,000,000 and $2,000,000 if the exemption does not increase to $2,000,000 in 2016. Accordingly, under the current version of the TRC Act, the highest tax rate of 16% would apply to the portion of the taxable estate between $1,000,000 and $2,000,000, which seems inconsistent with the D.C. Council’s intent. It is anticipated that the D.C. Council will pass technical amendments to the TRC Act prior to 2016 to correct this oversight. C. What the TRC Act Did Not Do. Although the TRC Act makes significant changes to the estate tax law that will eventually benefit its residents and individuals that own D.C. property, there are a couple of notable changes that were not made. 1. No Repeal of D.C. Estate Tax. The TRC Act does not repeal the D.C. estate tax.2 After the new law is fully phased in, the D.C. estate tax will remain applicable for estates over $5,000,000, as indexed for inflation. For estates above $10,000,000, the combined federal and D.C. estate tax rate will be 49.6%. 2. No Portability of D.C. Estate Tax Exemption. In 2010, the federal estate tax law introduced the concept of portability, which allows a surviving spouse to take advantage of the deceased spouse’s unused applicable exclusion amount (DSUE) by making an election on the deceased spouse’s estate tax return. The TRC Act does not permit portability of the D.C. estate tax exemption. III. Effect of New D.C. Estate Tax Law on Your Estate Plan. D.C. residents should revisit their estate plans to determine if the new D.C. estate tax law necessitates making any changes to their existing plans. D.C. residents with modest estates (i.e., $1,000,000 to $5,000,000) should not rely on estate tax relief in the near future and should continue to use tax planning techniques to address the D.C. estate tax. As the 2 Even if Congress repeals the federal estate tax in the future, which we do not expect, the D.C. estate tax will remain applicable to D.C. resident decedents and non-resident decedents who own D.C. situs property at death. Copyright 2015 McArthur Franklin PLLC Page 2 All Rights Reserved. effective date of the increased D.C. estate tax exemption is uncertain, D.C. residents should ensure that their estate plans provide sufficient flexibility to accommodate future changes to the D.C. estate tax exemption. If you have any questions about the new D.C. estate tax law or its potential effect on your estate plan, please contact one of our lawyers. VIRGINIA A. McARTHUR bio RICHARD S. FRANKLIN bio [email protected] [email protected] MOLLY B.F. WALLS bio [email protected] DISCLAIMER: This material is not intended to constitute a complete analysis of all tax or legal considerations. This material is not intended to provide financial, tax, legal, accounting, or other professional advice. Consult with your professional adviser to obtain counsel based on your individual circumstances. Copyright 2015 McArthur Franklin PLLC Page 3 All Rights Reserved. .
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