Preparing for the Wave of Tax Law Change

Thomas Kelley, CPA, CFP®, AEP® Director of Income Tax Planning Wilmington Trust, N.A.

Cailin MacLean Wealth Planning Analyst Wilmington Trust, N.A.

Key points • As fiscal stimulus and relief plans continue, Congress and the presidential administration have given guidance on how the revenue needs will be met

• With highly anticipated potential tax law changes on the horizon, it may be wise to review proposals that could affect your future planning

• As of May 28, 2021, the Department of the Treasury published the "Green Book," which provides more detailed information regarding the proposals coming from the presidential administration With President Biden’s first 100 days in office behind him, revisiting the proposals made during his campaign pertaining to income and transfer tax As we await further legislation is worth doing. These proposals, while not enacted, are important guidance on potential to review and consider before any planning strategies are implemented in 2021 as they represent potential changes to current tax laws.

tax law changes, now The most recent Treasury report released on May 28, 2021, an annual report commonly referred to as the "Green Book," gives a general explanation of the may be an important Biden administration's fiscal year 2022 revenue proposals for "the American Jobs Plan" and "the American Families Plan" and provides new details on time to be proactive proposed items impacting corporate and individual taxes.

with your tax planning The table on the following pages identifies key areas of income and transfer tax law affecting individuals and families, workers, corporations, and pass-through by familiarizing business entities, as well as those estates potentially subject to federal estate tax. Each of these areas explains the basic tax treatment under current or proposed yourself with proposed tax law, highlights key provisions or key considerations, and identifies potential planning considerations. items that may impact Please note that certain terminology may be used that requires further or future

M EMBER OF TH E M & T F A M I L Y M EMBER OFM TEMH EBER M & OFT F TAHM IEL YM & T F A M I L Y your future planning. specificity. For example, a proposal may use the term “filers” and may not delineate whether that denotes a filing status of single, married filing jointly, or Tax lawTax andTax law lawplanning and andanother planning planningtype opportunities of filer. opportunities opportunities Election-yearElection-year taxElection-year proposals tax thattaxproposals proposalscould affectthat that could your could affectfuture affect your planning your future future planning planning

Federal income tax rates on long-term capital gains (assets held for more than one year) Federal incomeFederal taxFederal rates income onincome long-termtax rates tax rates on capital long-term on long-termgains capital(assets capital gainsheld gains for (assets more (assets held than heldfor one more for year) more than thanone year)one year)

CURRENT CURRENTCURRENT TRUMP TRUMPTRUMPKEY KEY KEY PLANNING PLANNINGPLANNING TAX LAWLAW TAX LAWTAX LAW RECORDPROPOSED PLANRECORDRECORDCONSIDERATIONSCONSIDERATIONSCONSIDERATIONSOPPORTUNITIESOPPORTUNITIESOPPORTUNITIES The maximum federalThe maximum The maximum federalThe federal maximum The maximumThe Salesmaximum of businessesSales or Salesof businesses of businessesSales or of orbusiness Sales interests Salesof business may of business interests interests may may Thelong-term maximum capital federallong-term gains long-term rate capital is capitalcapital gainsFor gainsrate gains tax is rate taxfilers iscapital withcapital gains incomesales gainstax of oflarge tax holdingsSalessales ofsalesof largebusinesses of holdingslargereduce holdings or of sales tax ofby of sellingreduce• ownershipSalesreduce tax byof tax businessselling by selling ownership interests ownership may capital20%. For gains 2020 rate this20%. is applies20%; For20%. for 2020 to For2021 2020this rate applies thiswasover applies not to$1,000,000 changed torate was rate the not investmentwas long-term changed not changed assets largeinvestment may holdings investment assets of assets in investmentmay installments may inin any installments yearreducein installments in tax in byany selling in year any in ownershipyear in thisincomes applies over to $434,550incomesincomesincomes over for over $434,550 overby $434,550thecapital 2017for Tax forgains Cutsby rate the by 2017for thesubject gains Tax2017 Cuts in partTax Cutsof theassets subject subject may part subject of part thewhich of partthe a oflarge the gain which is anticipatedinwhich a installmentslarge a gainlarge is gain anticipated is anticipated single taxpayers and and Jobs Act transaction to a much the timing (or bunching) of $445,850 for singlesingle taxpayerssingle taxpayers taxpayers and and excessand of thisand amount Jobsand ActJobs will Act be transactiontransactiontransaction toto a a much much to a much higher the timingthe timing (or bunching) (or bunching) of of $488,850 for those$488,850 married$488,850 for those for thosemarried married higher income taxhigher ratehigher income income taxcharitable rate tax rate or othercharitable tax• In charitable any or year other or in othertaxwhich tax a large $501,600 for those married filing taxed at 39.6%; the NIIT of 3.8% income tax rate filing jointly. The Netfiling Invest jointly.filing- jointly. The Net The Invest NetBIDEN Invest- - BIDENBIDEN deductions may bedeductions gaindeductions is may anticipated be may be the timing jointly;ment Income the Net Tax Investmentment (NIIT) mentIncome of Income Income Tax (NIIT) Taxwill (NIIT) ofPLAN apply of for a totalPLAN maximumPLAN advantageous advantageous(oradvantageous bunching) of charitable or Tax3.8% (NIIT) applies of 3.8%so the3.8% applies total applies3.8% applies so the so total thecapital total gains rate of 43.4% For tax filers withFor taxFor filers tax withfilers with One may delay harvestingOne mayotherOne delay may tax delaydeductionsharvesting harvesting may be maximum rate is maximum23.8%maximum rate is rate 23.8% is 23.8% so the total maximum rate is 23.8%income of over incomeincome of over of over capital losses potentiallycapitaladvantageouscapital losses losses potentially potentially $1,000,000 the $1,000,000$1,000,000 the the planned for the taxplanned yearplanned 2020 for the tofor tax the year tax 2020 year 2020to to • One may delay harvesting long-term capitallong-term gainslong-term capital capital gains gains a future year thata anticipatedfuturea future year taxthat year anticipated that anticipated tax tax capital losses potentially TREASURY "GREEN BOOK" rateEXPLANATION for gains in excessrate for rate gains for gainsin excess in excess rates will be higherrates willrates be will higher be higher of this amount willof bethis of amount this amount will be will be planned for the tax year 2021 to Consider selling appreciatedConsiderConsider selling selling appreciated appreciated The “Green Book” provides thattaxed proposed at 39.6%; tax thelawtaxed NIITchanges taxedat 39.6%; atinclude 39.6%; the NIIT recognition the NIIT of capital gain income assets in the currentassets yearaassets in future ifthe incurrent year the currentwhen year anticipated if year if of 3.8% will applyof for 3.8% aof will3.8% apply will applyfor a for a upon certain events such as gifting of appreciated assets or assets received by beneficiariescurrent from ratesa are currentanticipatedtaxcurrent rates rates to arerates will anticipated beare higher anticipated to to total maximum capitaltotal maximum total maximum capital capital decedent’s estate. That is, although no sale or exchange of assets may actually occur, the proposalbe lower will be lowerbe lower gains rate of 43.4% • Consider selling appreciated treat the event as if a taxable transaction has occurred.gains gainsrate The of rate donor43.4% of 43.4%or decedent owner would incur the Use a charitable remainderUse a assetsUsecharitable a trust charitable in the remainder current remainder year trust if trust income tax realization liability. A $1,000,000 exclusion of gain recognition would apply to each person. for diversificationfor and diversification currentfortax diversification rates and are taxanticipated and tax to In addition, exclusions and exclusion amounts would apply to transfers to a spouse, charity, and mitigation of highlymitigation appreciatedbemitigation lower of highly of highly appreciated appreciated involving certain assets such as a personal residence. A 15-year income tax payment plan isassets provided for assetsassets certain family-owned assets. This proposed measure would be effective for gains on property • Consider using a charitable transferred by gift, and on property owned at death by decedents dying, after December 31, 2021. remainder trust for Federal incomeFederal taxFederal rates income onincome ordinarytax rates tax ratesincome on ordinary on ordinary income income diversification and tax The “Green Book” further confirms that long-term capital gains and qualified dividends of taxpayers mitigation of highly with adjustedCURRENT gross incomeCURRENTCURRENT of more than TRUMP $1,000,000 willTRUMP be taxedTRUMPKEY at ordinary incomeKEY taxKEY rates.PLANNING The PLANNINGappreciatedPLANNING assets "GreenTAX Book" LAW indicatesTAX this LAW TAXproposal LAW wouldRECORD be effectiveRECORD for RECORDgainsCONSIDERATIONS required to be recognizedCONSIDERATIONSCONSIDERATIONS afterOPPORTUNITIES the OPPORTUNITIESOPPORTUNITIES Thedate maximum of announcement. federalThe maximum The maximum “Date federal Taxof Announcement” federalbrackets wereTax may bracketsTax be bracketsThe the were lower April were current28, 2021The ordinary date lowerThe that lowercurrent announced currentIn ordinary a year ordinarythe of higher In incomea yearIn a of yearor higher of higher income income or or long-termAmerican capital Familieslong-term gains Plan,long-term rate capital oris it may capitalchanged gains be thegainsrate by date is ratethe this 2017ischanged publication changed byincome the wasby 2017 taxthe released rates2017 incomeare on Mayincome tax 28, rates 2021. tax arerateslarge In either arefinancial transactions,large financiallarge notfinancial transactions, transactions, not not 20%.case For retroactive 2020 this20%. appliestax For20%. laws 2020 to Formay 2020this potentiallyTax applies Cutsthis applies and to be Jobsimplemented. toTax Act, CutsTax andCutsscheduled Jobs and Act,Jobs to expire Act,scheduled or scheduled to expire toonly expire or might or the capitalonly might onlygains might thebe capital the capital gains gainsbe be incomes over $434,550incomesincomes for over $434,550 overwith $434,550 the for top forbracket with thewith topsunset the bracket top as bracket of 12/31/2025; sunsetsunset asif of 12/31/2025;as oftaxed 12/31/2025; at if a higher if taxed rate but taxedat amay higher at a higher rate but rate may but may single taxpayers andsingle single taxpayers taxpayers andreduced and to 37% reducedreduced tothis 37% would to 37% occur thisthe topwouldthis would occur occurthecause top the qualified top dividendscausecause qualified to bequalified dividends dividends to be to be $488,850 for those$488,850 married$488,850 for those for thosemarried married rate would revertrate to 39.6%; wouldrate would revert revert taxedto 39.6%; toat 39.6%;higher rates;taxed this taxedat higher at higher rates; rates;this this Continued filing jointly. The Netfiling Invest jointly.filing- jointly. The Net The Invest NetBIDEN Invest- - BIDENhowever,BIDEN the qualifiedhowever, however, the qualified thereinforces qualified the needreinforces to reinforcescarefully the need the toneed carefully to carefully ment 1 Income©2021 Taxment M&T(NIIT) BankmentIncome of Corporation Income Tax (NIIT) Tax and (NIIT) ofPLAN its subsidiaries.of PLANAlldividend rightsPLAN reserved. rates aredividend not dividend rates areratesconsider not are not the timingconsider andconsider income the timing the timing and income and income 3.8% applies so the3.8% total applies3.8% applies so theThe so total maximumthe total federalThe maximum The scheduledmaximum federal tofederal expirescheduled scheduled to expire torecognition expire and therecognition userecognition of and the and use the of use of tax rate for the highesttax ratetax for rate the for highest the highest available tax deductionsavailableavailable and tax deductions tax deductions and and tax bracket will betax brackettax bracket will be will be credits; the opportunitycredits;credits; isthe to opportunity the opportunity is to is to increased to 39.6%increasedincreased to 39.6% to 39.6% determine how accelerationdeterminedetermine how or acceleration how acceleration or or deferral of these deferralitemsdeferral may of thesebe of theseitems itemsmay be may be NOTE: Currently, qualifiedNOTE: NOTE:Currently, Currently, qualified qualified most advantageousmost advantageousmost advantageous dividends are taxeddividends at dividends are taxed are attaxed at preferred equivalentpreferred preferred equivalent equivalent Contribute fully toContribute all Contribute fully to fully all to all long-term capital gainslong-term long-term capital capital gains gains tax-advantaged accountstax-advantagedtax-advantaged such accounts accounts such such rates; for tax filers withrates; forrates; tax forfilers tax with filers with income over $1,000,000income income over $1,000,000 over $1,000,000 as Health Savingsas Accounts, Healthas Health Savings 529 Savings Accounts, Accounts, 529 529 qualified dividends qualifiedin qualified dividends dividends in in College EducationCollege Plans,College Education Education Plans, Plans, excess of this amountexcess will excessof this ofamount this amount will will retirement plans,retirement etc. retirement plans, plans, etc. etc. increase from 23.8%increase to increase from 23.8% from to23.8% to 43.4%; the dividends43.4%; will be43.4%; the dividends the dividends will be will be taxed at ordinary incometaxed attaxed ordinary at ordinary income income tax rates tax ratestax rates More on next pageMore onMore next on page next page M EMBER OF TH E M & T F A M I L Y M EMBER OFM TEMH EBER M & OFT F TAHM IEL YM & T F A M I L Y

Tax law TaxandTax lawplanning law and and planning opportunities planning opportunities opportunities Election-year taxElection-year proposalsElection-year taxthat taxproposals could proposals affect that yourthat could futurecould affect affectplanning your your future future planning planning

Federal income taxFederal ratesFederal incomeon long-term income taxFederal rates tax capital incomerates on long-term gainson tax long-term rates(assets capital on heldordinarycapital gains for gainsmore income(assets (assetsthan held one heldfor year) more for more than thanone year)one year)

CURRENT CURRENTCURRENT TRUMP TRUMPKEYTRUMP KEY KEYPLANNING PLANNINGPLANNING TAX LAWLAW TAX LAWTAX LAWRECORDPROPOSED PLANRECORDCONSIDERATIONSRECORD CONSIDERATIONSCONSIDERATIONSOPPORTUNITIES OPPORTUNITIESOPPORTUNITIES The maximum federal The maximumThe maximumThe federal maximum federal The maximumSalesThe maximum of businesses orSales Salesof businesses ofSales businesses of or business or interestsSales maySalesof business of business interests interests may may Thelong-term current capital maximum gainslong-term federal ratelong-term is capitalcapital capital Thegains gains maximum gainsrate tax is rate federaliscapital salescapital gainstax of rate gainslargetax holdingstax Thesales of lower ofsales large currentofreduce holdingslarge ordinaryholdings tax of by selling of ownershipreduce• reduceIn tax a year by tax selling of by higher selling ownership income ownership or income20%. For tax 2020 rate this is 37%, applies20%. with Forto20%. 2020 Forrate 2020this wasfor applies thethisnot highestchangedapplies to to tax rate bracket wasinvestmentrate not was willchanged not assets changed mayincomeinvestment investment tax assets ratesin installments assets aremay scheduled may in any inyear installments ininlarge installments financial in any in yeartransactions, any in year in severalincomes brackets over $434,550 that areincomes for graduated incomes overby $434,550 over thebe 2017$434,550 increased forTax Cuts for to by39.6% thesubjectby 2017 the Tax2017part Cuts ofTax the Cuts tosubject expiresubject part (or ofwhich sunset)part the of a thelarge as of gain is anticipatedwhichwhich nota large only a gainlarge might is gain anticipated the is capital anticipated orsingle increased taxpayers based and on single taxablesingle taxpayers taxpayersand Jobsand Actand and Jobstransactionand ActJobs Act to a much12/31/2025;transaction transaction to theif a this muchtiming to occurs, a much (or bunching) the the oftimingthe gains timing (or be bunching) taxed (or bunching) at a of higher of $488,850 for those married$488,850$488,850 for those for thosemarried married higher income tax ratehigherhigher income incomecharitable tax rate tax or rate other taxcharitable charitable or other or othertax tax income and filing status NOTE: Currently, qualified dividends top rate would revert to 39.6%; rate, but also qualified filing jointly. The Net Investfiling -jointly.filing jointly. The Net TheBIDEN Invest Net Invest- - BIDENBIDEN deductions may be deductionsdeductions may be may be ment Income Tax (NIIT)ment of mentIncome Income Tax are(NIIT) TaxPLAN taxed (NIIT) of at of preferred equivalentPLANPLAN however, theadvantageous qualified dividend advantageousadvantageousdividends may be taxed at 3.8% applies so the total3.8% applies3.8% applies so thelong-term so total the total capital gains rates; for tax rates are not scheduled to higher rates; this reinforces For tax filers with For taxFor filers tax withfilers with One may delay harvestingOne mayOne delay may delayharvesting harvesting maximum rate is 23.8%maximummaximum rate is rate 23.8%filers is 23.8% with income over $1,000,000 income of over incomeincome of over of over expire capital losses potentiallycapital capitalthe losses need losses potentially to carefully potentially consider $1,000,000qualified the dividends$1,000,000 in$1,000,000 excess the of thethis planned for the tax yearplanned 2020plannedthe forto timing the for tax andthe year taxincome 2020 year 2020to to long-termamount capital may gains increaselong-term long-term from capital 23.8% capital gains to gains a future year that anticipateda futurearecognition future taxyear that year anticipated andthat theanticipated use tax of tax rate for43.4%; gains the in excess dividendsrate for ratewill gains forbe gainstaxedin excess in at excess rates will be higher rates willratesavailable be will higher be tax higher deductions and of this amount will be of thisof amount this amount will be will be ordinary income tax rates Consider selling appreciatedConsiderConsidercredits; selling the selling appreciated opportunity appreciated is to taxed at 39.6%; the NIITtaxed taxedat 39.6%; at 39.6%; the NIIT the NIIT assets in the current yearassets if assetsdetermine in the incurrent the how current year acceleration if year if or of 3.8% will apply for aof 3.8%of will3.8% apply will applyfor a for a current rates are anticipatedcurrentcurrent torates arerates anticipated are anticipated to to total maximum capitaltotal maximumtotal maximum capital capital deferral of these items may be be lower be lowerbe lower TREASURY "GREEN BOOK" EXPLANATIONgains rate of 43.4% gains gainsrate of rate 43.4% of 43.4% most advantageous Use a charitable remainderUse a Usetrustcharitable a charitable remainder remainder trust trust “For 2021, the 37 percent marginal individual income tax rate applies to taxable income over $628,300 for • Consider contributing to all for diversification andfor tax diversification for diversification and tax and tax married individuals filing a joint return and surviving spouses, and $523,600 for unmarried individuals (other mitigation of highly appreciatedmitigationmitigationtax-advantaged of highly of highly appreciated accounts appreciated than surviving spouses) and head of household filers.” such as health savings M EMBER OF TH E M & T F A M I L Y M EMBER OFM TEMH EBER M & OFT F TAHM IEL YM & T F A M I L Y assets assetsassets The “Green Book” explains that this new top tax rate would start at the 2017 tax bracket threshold, adjusted accounts, 529 college education plans, retirement for inflation. Thus, the new highestFederal tax rates income may apply taxFederal to rates lowerFederal income ontaxable ordinary income income tax rates tax incomethreshold rates on ordinary amounts.on ordinary income income plans, etc. The proposal wouldTax be effective lawTax for andTaxtaxable law years lawplanning beginningand and after planning December planning opportunities 31, 2021. opportunities opportunities CURRENT CURRENTCURRENT TRUMP TRUMPKEYTRUMP KEY KEYPLANNING PLANNINGPLANNING TAX LAWElection-yearTAXElection-year LAWtaxTAXElection-year LAWproposalsRECORD tax thattaxproposals proposalscouldRECORDCONSIDERATIONSRECORD affectthat that could your could CONSIDERATIONS affectfuture CONSIDERATIONSaffect OPPORTUNITIESyour planning your future future planningOPPORTUNITIES planningOPPORTUNITIES The maximum federal The maximumThe maximumTax federal brackets federal were Tax bracketsTheTax lowerbrackets were current were ordinary The lower The lowercurrentIn a current year ordinary of ordinary higher income In a year orIn a of year higher of higher income income or or long-term capital gainslong-term ratelong-term is capitalItemizedchanged capital gains by deductionsgainsrate the is2017 rate ischanged forincomechanged individuals—notby thetax by 2017rates the 2017are income businessincome tax rateslarge tax or arerates financialrental are expensestransactions,large financiallarge not financial transactions, transactions, not not 20%. ForFederal 2020 this income applies20%.Federal Forto20%.tax Federal 2020 ratesFor Taxincome 2020this Cuts onincome applies this and long-termtax appliesJobs torates tax Act, toratesTax on capital Cuts scheduledlong-termTax on andCuts long-termgains Jobs and to expire capitalAct,(assetsJobs capitalAct,orscheduled gains heldscheduled gains for (assets to onlymore expire (assets to might heldexpire orthan the held foror one capital more for year)only gainsmore than mightonly be thanone might the year)onecapital the year)capital gains gainsbe be incomes over $434,550incomes for incomes overwith $434,550 over the $434,550 top for bracket for with thesunsetwith top the as bracket topof 12/31/2025; bracket sunset if sunset as of 12/31/2025;taxedas of 12/31/2025; at a higher if ifrate taxed but may taxedat a higher at a higher rate but rate may but may single taxpayers and singlesingle taxpayers taxpayersreduced and to and 37% reducedthisreduced towould 37% to occur 37% the topthis wouldthis would occurcause occurthe qualified top the top dividendscause tocause qualified be qualified dividends dividends to be to be CURRENT TRUMP KEY PLANNING $488,850CURRENT for those married$488,850CURRENT$488,850 CURRENT for those for thosemarried married TRUMPrate TRUMPwould revert to 39.6%;rateKEY would rate KEY would reverttaxed revert to at 39.6%; higher to 39.6%; rates; taxedPLANNINGthis taxedPLANNINGat higher at higher rates; rates;this this TAX LAWLAW TAX LAWTAX LAW RECORDPROPOSED PLANRECORDRECORDCONSIDERATIONSCONSIDERATIONSCONSIDERATIONSOPPORTUNITIESOPPORTUNITIESOPPORTUNITIES filing jointly. The Net Investfiling -jointly.filing jointly. The Net TheBIDEN Invest Net Invest- - however,BIDENBIDEN the qualifiedhowever, however, the reinforcesqualified the qualified the need toreinforces carefullyreinforces the need the toneed carefully to carefully mentThe maximum Income Tax federalThe (NIIT) maximum mentThe of maximummentIncome federal IncomeThe Tax federal maximum (NIIT) TaxPLAN (NIIT) of The of maximumThe dividendSalesmaximumPLAN of PLANbusinesses rates areSales not ordividend Salesof businessesdividend of ratesbusinessesconsiderSales areorrates notof are orbusiness the not timingSales interests andconsider Salesof income business mayconsider of thebusiness intereststiming the intereststiming and may income and may income long-term capitallong-term gainslong-term rate capital is capitalcapital gains gainsrate gains is rate tax iscapital capital gainssales gainstax of large tax holdingssales ofsalesof large of holdingslargereduce holdings of tax ofby sellingreduce ownershipreduce tax by tax selling by selling ownership ownership The3.8% current applies law so thesuspends total3.8% the applies3.8% appliesThe so the maximum• so totalThe the "Pease" total federal limitation The maximumscheduledThe wouldmaximum federal to expire federal• Statescheduled andscheduled local torecognition expiretax to deductions expire and the • use recognitionAn of investor recognition and may the and be use the of use of 20%. For 2020 this20%. applies For20%. 2020 to For 2020thisrate applies thiswas applies not to changed torate was rate not investmentwas changed not changed assets investment may investment assets assetsin may installments may inin any installments yearin installments in in any in year any in year in existing “Pease” limitations for tax rate befor restoredthe highest fortax filers ratetax for ratewith the for highest the highest may continue toavailable be limited tax todeductions availablemaintaining andavailable tax deductions debt tax deductionswhile and and incomes over $434,550incomesincomes for over $434,550 overby $434,550the 2017for Tax for Cutsby the by 2017 thesubject Tax2017 Cuts partTax Cutsof the subject subject part of part thewhich of the a large gainwhich is anticipatedwhich a large a gainlarge is gain anticipated is anticipated taxpayers in higher tax brackets tax bracketincomes will be greater tax bracketthantax bracket will be will be a maximum of credits;$10,000 the per opportunity credits;holding is tocredits; the investment opportunity the opportunity assets; is to is to single taxpayers andsingle single taxpayers taxpayers andand Jobs and Act and Jobsand ActtransactionJobs Act to a muchtransaction transaction to a much tothe a timing much (or bunching)the timingthe of timing (or bunching) (or bunching) of of increased$400,000 to 39.6% increasedincreased to 39.6% to 39.6%year determine how accelerationdeterminethosedetermine orassets how may acceleration how be acceleration or or $488,850 for those$488,850 married$488,850 for those for thosemarried married higher income taxhigher ratehigher income income taxdeferralcharitable rate tax rate of orthese other charitableitems taxdeferral charitablemay deferralor be ofother theseor ofothertax theseitems tax itemsmay be may be NOTE: Currently, qualifiedNOTE: NOTE:Currently, Currently, qualified qualified producing investment income filing jointly. The Netfiling Invest jointly.filing- jointly. The Net The Invest •Net BIDENDeductions Invest- - limitedBIDEN toBIDEN a 28% • Mortgage and mostdeductionsinvestment advantageous may bedeductions mostdeductions advantageousmost may advantageousbe may be ment Income Taxment (NIIT) mentIncome of Income Taxdividends (NIIT) Tax (NIIT) ofPLAN are taxedof at dividendsPLANdividendsPLAN are taxed are attaxed at advantageous advantageouswhileadvantageous the debt is incurring preferredtax equivalent benefit preferredpreferred equivalent equivalent interest expense deductions 3.8% applies so the3.8% total applies3.8% applies so the so total the total Contribute fully to all ContributeinvestmentContribute fully interest to fully all expense;to all Forlong-term tax filers capital with gainsFor taxlong-termFor filers taxlong-term withfilers capital with capital gains gainsmay be limitedtax-advantagedOne to some may delay harvesting accountsOne tax-advantagedmayOne such delay tax-advantagedmay delayharvesting accountsharvesting accounts such such maximum rate is maximum23.8%maximum rate is rate incomerates;23.8% is • for23.8% Anyoftax over filers allowed with deductionsrates; forrates; tax forfilers after tax with filers with if the investment income incomeincome of over of over degree going forwardascapital Health losses Savings potentiallycapital Accounts,ascapital lossesHealth as 529 lossesHealth potentially Savings potentially Savings Accounts, Accounts, 529 529 $1,000,000income overapplying $1,000,000 the $1,000,000 any incomeother$1,000,000income limitations overthe $1,000,000 overthe $1,000,000 qualified dividends in qualifiedqualified dividends dividends in in Collegeplanned Educationfor the taxplanned Plans, yearCollegecausesplanned 2020 forCollege the Education higher tofor tax the Education year income tax Plans, 2020 year taxPlans, 2020to to excesslong-term ofwould this capital amount belong-term gainslimited willexcess long-term in excesscapital ofbenefit this capitalofamount gains this amount gains will will retirementa future year plans, thata etc. anticipatedfutureretirementthresholdsa future yearretirement taxthat year plans, and anticipated that plans, theetc. anticipated debt etc. tax tax increaserate for fromequalgains 23.8% into excess rateno to greater forincrease rate gains forincrease than from gainsin excess the23.8% from in excess to23.8% to rates will be higherrates willexpenserates be will higher isbe not higher fully of43.4%; this theamount dividends willof will bethis 43.4%;beof amount this43.4%; the amount dividends will the be dividends will will be be will be 28% tax bracket; for example, Consider selling appreciatedConsiderConsider selling selling appreciated appreciated taxed at at ordinary 39.6%; incomethetaxed NIITtaxed taxedat 39.6%; attaxed atordinary 39.6%; theat ordinary NIIT income the NIIT income deductible, one may consider tax rates tax ratestax rates assets in the currentassets yearassets in ifthe incurrent the current year if year if More on next page More onMore next onof page next3.8% page awill person applyof infor 3.8%a a39.6%of will3.8% taxapply will applyfor a for a exterminating debt to improve current rates are currentanticipatedcurrent rates to arerates anticipated are anticipated to to total maximumbracket capital subjecttotal maximum total to thismaximum capital capital after-tax investment holdings be lower be lowerbe lower gains ratelimitation of 43.4%gains would gainsrate only of rate 43.4% be of 43.4% • It may be fruitful to delay allowed a deduction equal to a Use a charitable remainderUse a Usecharitable a trust charitable remainder remainder trust trust deductions and/or bunch tax amount of 28% not 39.6% for diversificationfor and diversification fortax diversification and tax and tax mitigation of highlymitigation appreciateddeductionsmitigation of highly of in highly appreciatedthe year appreciated or assets assetsyearsassets when the best impact can be reaped Federal incomeFederal taxFederal rates income onincome ordinarytax rates tax ratesincome on ordinary on ordinary income income

CURRENT CURRENTCURRENT TRUMP TRUMPTRUMPKEY KEY KEY PLANNING PLANNINGPLANNING TAX LAW TAX LAWTAX LAW RECORD RECORDRECORDCONSIDERATIONSCONSIDERATIONSCONSIDERATIONSOPPORTUNITIESOPPORTUNITIESOPPORTUNITIES The maximum federalThe maximum The maximum federalTax federalbrackets wereTax bracketsTax bracketsThe were lower were current The ordinary lowerThe lowercurrent currentIn ordinary a year ordinary of higher In incomea yearIn a of yearor higher of higher income income or or long-term capitallong-term gainslong-term rate capital is capitalchanged gains gainsrate by is ratethe 2017ischanged changed byincome the by 2017 taxthe rates2017 incomeare income tax rates tax arerateslarge arefinancial transactions,large financiallarge notfinancial transactions, transactions, not not 20%. For 2020 this20%. applies For20%. 2020 to For 2020thisTax applies Cutsthis applies and to Jobs toTax Act, CutsTax andCutsscheduled Jobs and Act,Jobs to expire Act,scheduled or scheduled to expire toonly expire or might or the capitalonly might onlygains might thebe capital the capital gains gainsbe be incomes over $434,550incomesincomes for over $434,550 overwith $434,550 the for top forbracket with thewith topsunset the bracket top as bracket of 12/31/2025; sunsetsunset asif of 12/31/2025;as oftaxed 12/31/2025; at if a higher if taxed rate but taxedat amay higher at a higher rate but rate may but may single taxpayers andsingle single taxpayers taxpayers andreduced and to 37% reducedreduced tothis 37% would to 37% occur thisthe topwouldthis would occur occurthecause top the qualified top dividendscausecause qualified to bequalified dividends dividends to be to be $488,850 for those$488,850 married$488,850 for those for thosemarried married rate would revertrate to 39.6%; wouldrate would revert revert taxedto 39.6%; toat 39.6%;higher rates;taxed this taxedat higher at higher rates; rates;this this filing jointly. The Netfiling Invest jointly.filing- jointly. The Net The Invest NetBIDEN Invest- - BIDENhowever,BIDEN the qualifiedhowever, however, the qualified thereinforces qualified the needreinforces to reinforcescarefully the need the toneed carefully to carefully ment Income Taxment (NIIT) mentIncome of Income Tax (NIIT) Tax (NIIT) ofPLAN of PLANdividendPLAN rates aredividend not dividend rates areratesconsider not are not the timingconsider andconsider income the timing the timing and income and income 3.8% applies so the3.8% total applies3.8% applies so theThe so total maximumthe total federalThe maximum The scheduledmaximum federal tofederal expirescheduled scheduled to expire torecognition expire and therecognition userecognition of and the and use the of use ofContinued tax rate for the highesttax ratetax for rate the for highest the highest available tax deductionsavailableavailable and tax deductions tax deductions and and credits; the opportunitycredits;credits; isthe to opportunity the opportunity is to is to 2 ©2021 M&T Bank Corporationtax bracket and its will subsidiaries. betax brackettax All bracket rights will be reserved. will be increased to 39.6%increasedincreased to 39.6% to 39.6% determine how accelerationdeterminedetermine how or acceleration how acceleration or or deferral of these deferralitemsdeferral may of thesebe of theseitems itemsmay be may be NOTE: Currently, qualifiedNOTE: NOTE:Currently, Currently, qualified qualified most advantageousmost advantageousmost advantageous dividends are taxeddividends at dividends are taxed are attaxed at preferred equivalentpreferred preferred equivalent equivalent Contribute fully toContribute all Contribute fully to fully all to all long-term capital gainslong-term long-term capital capital gains gains tax-advantaged accountstax-advantagedtax-advantaged such accounts accounts such such rates; for tax filers withrates; forrates; tax forfilers tax with filers with income over $1,000,000income income over $1,000,000 over $1,000,000 as Health Savingsas Accounts, Healthas Health Savings 529 Savings Accounts, Accounts, 529 529 qualified dividends qualifiedin qualified dividends dividends in in College EducationCollege Plans,College Education Education Plans, Plans, excess of this amountexcess will excessof this ofamount this amount will will retirement plans,retirement etc. retirement plans, plans, etc. etc. increase from 23.8%increase to increase from 23.8% from to23.8% to 43.4%; the dividends43.4%; will be43.4%; the dividends the dividends will be will be taxed at ordinary incometaxed attaxed ordinary at ordinary income income tax rates tax ratestax rates More on next pageMore onMore next on page next page M EMBER OF TH E M & T F A M I L Y M EMBER OFM TEMH EBER M & OFT F TAHM IEL YM & T F A M I L Y

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CURRENT CURRENTCURRENT TRUMP TRUMPTRUMPKEY KEY KEY PLANNING PLANNINGPLANNING TAX LAWLAW TAX LAWTAX LAW RECORDPROPOSED PLANRECORDRECORDCONSIDERATIONSCONSIDERATIONSCONSIDERATIONSOPPORTUNITIESOPPORTUNITIESOPPORTUNITIES The maximum federalThe maximum The maximum federalThe federal maximum The maximumThe Salesmaximum of businessesSales or Salesof businesses of businessesSales or of orbusiness Sales interests Salesof business may of business interests interests may may Forlong-term most assets capital (notlong-term gains retirementlong-term rate capital is capitalcapital gains• gainsrate gainsSubstantial is rate tax iscapital adjustmentcapital gainssales gainstax of of large thetax holdingsRecordssales ofsalesof large to ofdetermine holdingslargereduce holdings ofor tax ofby sellingreduce• ownershipItreduce taxmay by betax selling prudent by selling ownership to ownershipevaluate assets)20%. 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The Netfiling Invest jointly.filing- jointly. The Net The Invest NetBIDENcertain Invest- -assets mayBIDEN beBIDEN deductions may bedeductions deductions may be may be as measured on the date of death; expenses or charitable ment Income Taxment (NIIT) mentIncome of Income Tax (NIIT) Tax (NIIT) ofPLANstepped-up of to $1,000,000PLANPLAN advantageous advantageousadvantageous this3.8% permits applies the so thefamily3.8% total applies 3.8%or applies so the so total the total contributions by individuals For tax filers(there with mayFor be tax Forspecific filers tax withfilers with One may delay harvestingOne mayOne delay may delayharvesting harvesting beneficiariesmaximum rate notis maximum23.8% to incurmaximum capital rate is rate 23.8% is 23.8% prior to passing may have income situationsof over income and incomeasset of over holdings of over capital losses potentiallycapitalcapital losses losses potentially potentially gains upon the sale of the asset if greater tax efficiency if assets $1,000,000that the provide $1,000,000 for$1,000,000 stepped-up the the planned for the taxplanned yearplanned 2020 for the tofor tax the year tax 2020 year 2020to to sold at that fair market value long-term capitallong-term gainslong-term capital capital gains gains a future year thata anticipatedfuturewerea future year sold taxthat year to anticipated paythat thoseanticipated tax tax basis to higher allowed rate for gains in excessrate for rate gains for gainsin excess in excess rates will be higherrates willexpendituresrates be will higher be higher of this amountamounts). willof bethis of amount this amount will be will be Consider selling appreciatedConsiderConsider selling selling appreciated appreciated taxed at 39.6%; thetaxed NIIT taxedat 39.6%; at 39.6%; the NIIT the NIIT • For individuals subject to state assets in the currentassets yearassets in ifthe incurrent the current year if year if of 3.8% will applyof for 3.8% aof will3.8% apply will applyfor a for a estate taxes there may be an current rates are currentanticipatedcurrent rates to arerates anticipated are anticipated to to total maximum capitaltotal maximum total maximum capital capital be lower be loweropportunitybe lower to sell assets prior gains rate of 43.4%gains gainsrate of rate 43.4% of 43.4% to death so one’s gross estate Use a charitable remainderUse a Usecharitable a trust charitable remainder remainder trust trust for diversificationfor and diversification isfortax reduced diversification by and the tax andincome tax tax mitigation of highlymitigation appreciatedliabilitiesmitigation of highly incurred of highly appreciated appreciated assets assets• Reviewassets existing estate planning strategies and Federal incomeFederal taxFederal rates income onincome ordinarytax rates tax ratesincome on ordinary on ordinary income income documents that premise that stepped-up basis is available CURRENT CURRENTCURRENT TRUMP TRUMPTRUMPKEY KEY KEY PLANNING PLANNINGPLANNING TAX LAW TAX LAWTAX LAW RECORD RECORDRECORDCONSIDERATIONSCONSIDERATIONSCONSIDERATIONSOPPORTUNITIES• OPPORTUNITIESA removalOPPORTUNITIES of stepped-up basis TheTREASURY maximum "GREENfederalThe maximum The BOOK" maximum federal EXPLANATIONTax federalbrackets wereTax bracketsTax bracketsThe were lower were current The ordinary lowerThe lowercurrent currentIn ordinary a year ordinary of higher In incomea yearmayIn a of yearor be higher appropriate of higher income income or could or long-term capitallong-term gainslong-term rate capital is capitalchanged gains gainsrate by is ratethe 2017ischanged changed byincome the by 2017 taxthe rates2017 incomeare income tax rates tax arerateslarge arefinancial transactions,large substantiatefinanciallarge notfinancial transactions, the transactions, decision not to not Please note that in the federal income tax on capital gains section on page one there is proposed 20%. For 2020 this20%. applies For20%. 2020 to For 2020thisTax applies Cutsthis applies and to Jobs toTax Act, CutsTax andCutsscheduled Jobs and Act,Jobs to expire Act,scheduled or scheduled to expire toonly expire or might or the capitalonly might makeonlygains might thebea Roth capital the IRA capital gains conversion gainsbe be incomesMcapitalEMBER OF TH overEgain M & T F A $434,550MrecognitionI L Y incomesM EMBER incomesOF forM TEMH over EBERon M & OFT Fcertain T A$434,550H MoverIEL YM &withT F A$434,550 MsituationsI L Ythe for top forbracket with with assets thewith transferredtopsunset the bracket top as bracket of upon 12/31/2025; death.sunsetsunset Forasif of those 12/31/2025;as of assetstaxed 12/31/2025; at if a higher if taxed rate but taxedat amay higher at a higher rate but rate may but may singlethat taxpayersincur capital andsingle gains single taxpayers income taxpayers taxandreduced liability, and to 37%thosereduced assetsreduced should tothis 37% would to adjust 37% occur income thisthe tax topwouldthis basis would occur to the occurthecause fair top the qualified top dividendscause• Donatingcause qualified to bequalified dividendsappreciated dividends to beassets to be $488,850market valuefor those rather$488,850 married than$488,850 for potentially those for thosemarried be subjectmarried to any stepped-uprate would basis revert limitations.rate to 39.6%; wouldrate would revert revert taxedto 39.6%; toat 39.6%;higher rates;taxed this totaxedat charity higher at higher rates;during rates;this your this lifetime filing jointly. 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The Net The Invest NetBIDEN Invest- - BIDENhowever,BIDEN the qualifiedhowever, however, the qualified thereinforces qualified the needreinforces to mayreinforcescarefully thebecome need the moretoneed carefully torelevant carefully ment Income TaxmentTax (NIIT) mentIncome of lawIncome TaxTax (NIIT) Tax andTax (NIIT) ofPLAN law of lawplanning andPLAN dividendandPLAN planning rates planning areopportunitiesdividend not dividend rates areratesopportunitiesconsider not areopportunities not the timingconsider andconsider income the timing the timing and income and income 3.8% applies so the3.8% total applies3.8% applies so theThe so total maximumthe total federalThe maximum The scheduledmaximum federal tofederal expirescheduled scheduled to expire torecognition expire and therecognition userecognition of and the and use the of use of Election-yearElection-year taxtaxElection-year rate proposals for the highest taxtax rate taxthat taxproposals for rate the proposalscould for highest the highest affectthat that could your could affectfutureavailable affect your planning tax your futuredeductionsavailable future availableplanning and tax planning deductions tax deductions and and tax bracket will betax brackettax bracket will be will be credits; the opportunitycredits;credits; isthe to opportunity the opportunity is to is to increased to 39.6%increasedincreased to 39.6% to 39.6% determine how accelerationdeterminedetermine how or acceleration how acceleration or or Federal incomeFederal taxFederal rates income onincome long-termtax rates tax rates on capital long-term on long-termgains capital(assets capital gainsheld gains for (assets deferralmore (assets held than of these heldfor one deferralmoreitems for year) deferral moremay than of thesebe than oneof theseitems year)one itemsmay year) be may be NOTE:Section Currently, 199A qualifiedNOTE: deduction—qualified NOTE:Currently, Currently, qualified qualified business income deduction most advantageousmost advantageousmost advantageous dividends are taxeddividends at dividends are taxed are attaxed at preferred equivalentpreferred preferred equivalent equivalent Contribute fully toContribute all Contribute fully to fully all to all CURRENT CURRENTCURRENTlong-term TRUMP capital gainslong-term long-termTRUMP capitalTRUMP capital gainsKEY gains KEY KEYtax-advantagedPLANNING accountstax-advantagedPLANNINGtax-advantaged suchPLANNING accounts accounts such such TAX LAWLAW TAX LAWTAXrates; LAW for taxRECORD PROPOSEDfilers withrates; forrates; PLAN taxRECORD forfilers taxRECORD with filersCONSIDERATIONS with CONSIDERATIONSCONSIDERATIONSOPPORTUNITIESOPPORTUNITIESOPPORTUNITIES income over $1,000,000income income over $1,000,000 over $1,000,000 as Health Savingsas Accounts, Healthas Health Savings 529 Savings Accounts, Accounts, 529 529 The maximum federalThe maximum The maximum federalqualifiedThe federal maximum dividends qualifiedThein maximumqualifiedThe dividends Salesmaximum dividends of in businesses in Sales or Salesof businesses of businessesCollegeSales or of orEducationbusiness CollegeSales interests Plans, CollegeSalesof Educationbusiness may of Educationbusiness interests Plans, interests Plans, may may Forlong-term eligible capital taxpayerslong-term gains thelong-term rate capital is capitalexcesscapital gainsThis ofgainsrate gains this qualified is amountrate tax isexcesscapital will business excesscapitalof gains thissales ofamount gains taxincome this of largeamount tax will holdings willThissales current ofsalesof large of Section holdingslargeretirementreduce holdings of tax ofplans,by sellingretirementreduce etc. Businesses ownershipretirementreduce tax plans,by tax selling may plans, byetc. selling takeownership etc. upfront ownership 20%. For 2020 this20%. applies For20%. 2020 to For 2020thisrateincrease applies thiswas fromapplies not to 23.8%changed torateincrease to was rateincrease from not investmentwas 23.8%changed from not to23.8%changed assets to investment may investment assets assetsin may installments may inin any installments yearin installments in in any in year any in year in currentincomes law over provides $434,550incomes forincomes fora over $434,550 overby43.4%; $434,550thededuction the 2017for dividends Tax for Cuts phasesby43.4%; will the beby43.4%; the 2017 out the dividendssubject the forTax2017 dividends Cuts partTax will Cutsbeof willthe199A subject be provisionsubject part of part the applieswhich of the ato large gainwhich isdeductions anticipatedwhich a large a gainlarge or bonusis gain anticipated is anticipated potentialsingle taxpayers 20% qualified andsingle single taxpayers business taxpayers andandtaxed Jobs incomesandat ordinary Act in income andtaxedexcess Jobs atandtaxed ordinaryof ActtransactionJobs $400,000at ordinary Actincome incometo a muchpass-throughtransaction transaction to aentities much tothe a timing much such (oras bunching)the depreciationtimingthe of timing (or bunching) (or to bunching)reduce of income of tax rates tax ratestax rates incomeMore$488,850 on deduction next for thosepageMore$488,850 married onMore$488,850 next for on thosepage next for thosepagemarried married higher income taxpartnershipshigher ratehigher income income and taxcharitable Srate corporationstax rate or other charitable taxas charitablesoon or as other possible; or othertax whiletax filing jointly. 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Federal incomeFederal taxFederal rates income onincome ordinarytax rates tax ratesincome on ordinary on ordinary income income

CURRENT CURRENTCURRENT TRUMP TRUMPTRUMPKEY KEY KEY PLANNING PLANNINGPLANNING Continued TAX LAW TAX LAWTAX LAW RECORD RECORDRECORDCONSIDERATIONSCONSIDERATIONSCONSIDERATIONSOPPORTUNITIESOPPORTUNITIESOPPORTUNITIES The 3 maximum©2021 federalThe M&T maximum BankThe maximum Corporation federalTax federalbrackets and its subsidiaries. wereTax bracketsTax All bracketsThe rights were lower reserved. were current The ordinary lowerThe lowercurrent currentIn ordinary a year ordinary of higher In incomea yearIn a of yearor higher of higher income income or or long-term capitallong-term gainslong-term rate capital is capitalchanged gains gainsrate by is ratethe 2017ischanged changed byincome the by 2017 taxthe rates2017 incomeare income tax rates tax arerateslarge arefinancial transactions,large financiallarge notfinancial transactions, transactions, not not 20%. For 2020 this20%. applies For20%. 2020 to For 2020thisTax applies Cutsthis applies and to Jobs toTax Act, CutsTax andCutsscheduled Jobs and Act,Jobs to expire Act,scheduled or scheduled to expire toonly expire or might or the capitalonly might onlygains might thebe capital the capital gains gainsbe be incomes over $434,550incomesincomes for over $434,550 overwith $434,550 the for top forbracket with thewith topsunset the bracket top as bracket of 12/31/2025; sunsetsunset asif of 12/31/2025;as oftaxed 12/31/2025; at if a higher if taxed rate but taxedat amay higher at a higher rate but rate may but may single taxpayers andsingle single taxpayers taxpayers andreduced and to 37% reducedreduced tothis 37% would to 37% occur thisthe topwouldthis would occur occurthecause top the qualified top dividendscausecause qualified to bequalified dividends dividends to be to be $488,850 for those$488,850 married$488,850 for those for thosemarried married rate would revertrate to 39.6%; wouldrate would revert revert taxedto 39.6%; toat 39.6%;higher rates;taxed this taxedat higher at higher rates; rates;this this filing jointly. The Netfiling Invest jointly.filing- jointly. The Net The Invest NetBIDEN Invest- - BIDENhowever,BIDEN the qualifiedhowever, however, the qualified thereinforces qualified the needreinforces to reinforcescarefully the need the toneed carefully to carefully ment Income Taxment (NIIT) mentIncome of Income Tax (NIIT) Tax (NIIT) ofPLAN of PLANdividendPLAN rates aredividend not dividend rates areratesconsider not are not the timingconsider andconsider income the timing the timing and income and income 3.8% applies so the3.8% total applies3.8% applies so theThe so total maximumthe total federalThe maximum The scheduledmaximum federal tofederal expirescheduled scheduled to expire torecognition expire and therecognition userecognition of and the and use the of use of tax rate for the highesttax ratetax for rate the for highest the highest available tax deductionsavailableavailable and tax deductions tax deductions and and tax bracket will betax brackettax bracket will be will be credits; the opportunitycredits;credits; isthe to opportunity the opportunity is to is to increased to 39.6%increasedincreased to 39.6% to 39.6% determine how accelerationdeterminedetermine how or acceleration how acceleration or or deferral of these deferralitemsdeferral may of thesebe of theseitems itemsmay be may be NOTE: Currently, qualifiedNOTE: NOTE:Currently, Currently, qualified qualified most advantageousmost advantageousmost advantageous dividends are taxeddividends at dividends are taxed are attaxed at preferred equivalentpreferred preferred equivalent equivalent Contribute fully toContribute all Contribute fully to fully all to all long-term capital gainslong-term long-term capital capital gains gains tax-advantaged accountstax-advantagedtax-advantaged such accounts accounts such such rates; for tax filers withrates; forrates; tax forfilers tax with filers with income over $1,000,000income income over $1,000,000 over $1,000,000 as Health Savingsas Accounts, Healthas Health Savings 529 Savings Accounts, Accounts, 529 529 qualified dividends qualifiedin qualified dividends dividends in in College EducationCollege Plans,College Education Education Plans, Plans, excess of this amountexcess will excessof this ofamount this amount will will retirement plans,retirement etc. retirement plans, plans, etc. etc. increase from 23.8%increase to increase from 23.8% from to23.8% to 43.4%; the dividends43.4%; will be43.4%; the dividends the dividends will be will be taxed at ordinary incometaxed attaxed ordinary at ordinary income income tax rates tax ratestax rates More on next pageMore onMore next on page next page M EMBER OF TH E M & T F A M I L Y M EMBER OFM TEMH EBER M & OFT F TAHM IEL YM & T F A M I L Y

Federal incomeFederal taxFederal rates income onincome long-termtax rates tax rates on capitalSocial long-term on long-term gainsSecurity capital(assets tax capital on gainsheld wages gains for (assets more (assets held than heldfor one more for year) more than thanone year)one year)

M EMTheBER OF proposal THCURRENTE M & T F A M I L Y would M EMBER OFbeM TEMHCURRENT EBEReffective M & OFT F TAHCURRENTM IEL YM & T F A forM I L Y taxable TRUMP years beginningTRUMP TRUMPafterKEY December 31, 2021.KEY KEY PLANNING PLANNINGPLANNING TAX LAW TAX LAWTAX LAW RECORD RECORDRECORDCONSIDERATIONSCONSIDERATIONSCONSIDERATIONSOPPORTUNITIESOPPORTUNITIESOPPORTUNITIES The maximum federalThe maximum The maximum federalTax federalbrackets wereTax bracketsTax bracketsThe were lower were current The ordinary lowerThe lowercurrent currentIn ordinary a year ordinary of higher In incomea yearIn a of yearor higher of higher income income or or long-term capitallong-term gainslong-term rate capital is capitalchanged gains gainsrate by is ratethe 2017ischanged changed byincome the by 2017 taxthe rates2017 incomeare income tax rates tax arerateslarge arefinancial transactions,large financiallarge notfinancial transactions, transactions, not not 20%. For 2020 this20%.Tax applies For20%. 2020 to lawFor 2020thisTax applies CutsthisandTax applies and tolaw Jobs tolawTaxplanning Act, CutsandTax andCutsscheduledand Jobs and planning Act,Jobs to planningexpire Act,opportunitiesscheduled or scheduled to expire opportunities toonly expire oropportunities might or the capitalonly might onlygains might thebe capital the capital gains gainsbe be incomes over $434,550incomesincomes for over $434,550 overwith $434,550 the for top forbracket with thewith topsunset the bracket top as bracket of 12/31/2025; sunsetsunset asif of 12/31/2025;as oftaxed 12/31/2025; at if a higher if taxed rate but taxedat amay higher at a higher rate but rate may but may single taxpayersElection-year andsingle single taxpayers taxpayersElection-year and reducedtaxElection-year and proposals to 37% reducedtax reducedthattaxproposals tothis 37% proposalscould would to 37% occur affectthat thisthe that could topwould thisyour could would occur affectfuture occurthecause affect top yourthe qualifiedplanning top your future dividendscause future cause qualifiedplanning to bequalifiedplanning dividends dividends to be to be $488,850 for those$488,850 married$488,850 for those for thosemarried married rate would revertrate to 39.6%; wouldrate would revert revert taxedto 39.6%; toat 39.6%;higher rates;taxed this taxedat higher at higher rates; rates;this this however, the qualifiedhowever, however, the qualified the qualified filing jointly. The Netfiling Invest jointly.filing- jointly. The Net The Invest NetBIDEN Invest- - BIDENCorporateBIDEN income tax rate reinforces the needreinforces to reinforcescarefully the need the toneed carefully to carefully ment IncomeFederal Tax ment income(NIIT) mentIncome Federalof tax IncomeFederal Tax rates income(NIIT) Tax on income(NIIT) ofPLAN long-termtax of rates tax rates on capitalPLAN dividendlong-term onPLAN long-termgains rates capital(assets aredividend not capital dividend gainsheld rates gains for (assets arerates considermore not (assets are heldnot than the held fortiming one considermore for year)and considermore thanincome the timing thanone the timing year)oneand income year)and income 3.8% applies so the3.8% total applies3.8% applies so theThe so total maximumthe total federalThe maximum The scheduledmaximum federal tofederal expirescheduled scheduled to expire torecognition expire and therecognition userecognition of and the and use the of use of tax rate for the highesttax ratetax for rate the for highest the highest available tax deductionsavailableavailable and tax deductions tax deductions and and CURRENT CURRENTCURRENTtax bracket TRUMP will betax brackettaxTRUMP bracket willTRUMP be willKEY be KEY KEYcredits;PLANNING the opportunitycredits;PLANNINGcredits; isthe toPLANNING opportunity the opportunity is to is to TAX LAW TAX LAWTAX LAW RECORD RECORDRECORDCONSIDERATIONSCONSIDERATIONSCONSIDERATIONSOPPORTUNITIESOPPORTUNITIESOPPORTUNITIES TAX LAW increased toPROPOSED 39.6%increasedincreased PLAN to 39.6% to 39.6% CONSIDERATIONSdetermine how accelerationdeterminedetermine OPPORTUNITIEShow or acceleration how acceleration or or The maximum federalThe maximum The maximum federalThe federal maximum The maximumThe Salesmaximum of businessesSales or Salesof businesses of businessesdeferralSales or of orofbusiness these deferralSales itemsinterests deferralSales ofmay ofbusiness may thesebeof ofbusiness these itemsinterests itemsmayinterests may be may may be NOTE: Currently, qualifiedNOTE: NOTE:Currently, Currently, qualified qualified long-term capitallong-term gainslong-term rate capital is capitalcapital gains gainsrate gains is rate tax iscapital capital gainssales gainstax of large tax holdingssales ofsalesof large of holdingslargemostreduce holdings ofadvantageous tax ofby sellingmostreduce ownership advantageousmostreduce tax byadvantageous tax selling by selling ownership ownership Current C corporation tax rate dividendsThe are tax taxed ratedividends at will dividendsbe areincreased taxed are attaxed at • C corporations were Entrepreneurs may evaluate 20%. For 2020 this20%. applies For20%. 2020 to For 2020thisrate applies thiswas applies not to changed torate was rate not investmentwas changed not changed assets investment may investment assets assetsin may installments may inin any installments yearin installments in in any in year any in year in is 21% preferredto 28% equivalentpreferred preferred equivalent equivalent subject to the alternativeContribute fully toContribute allwhether Contribute fully C corporations to fully all to all or incomes over $434,550 for bylong-term the 2017 capital Tax gainsCutslong-term long-term capitalsubject capital gains part gains of the which a large gain is anticipated incomesincomes over $434,550 over $434,550 for for by theby 2017 the Tax2017 Cuts Tax Cuts subjectsubject part of part thetax-advantaged of the accountstax-advantagedwhichtax-advantagedwhich a large such a gainlarge accounts is gain anticipated accounts is such anticipated such single taxpayers and andrates; Jobs for tax Act filers withrates; forrates; taxtransaction forfilers tax with filers to with a muchminimum tax (AMT)the timing rule; (or bunching)pass-through of entities are the singlesingle taxpayers taxpayers and and and Jobsand ActJobs Act transactiontransaction to a much toas aHealth much Savings asthe Accounts, Health timingasthe Health timingSavings (or 529 bunching) Savings (or Accounts, bunching) Accounts, of 529 of 529 $488,850 for those$488,850 married$488,850 for those forincome thosemarried over married $1,000,000 income income overhigher $1,000,000 over income$1,000,000 taxhigher ratecertainhigher income tax income transactions taxcharitable rate tax rate andor other charitable taxmost charitable advantageous or other or othertax formstax of qualified dividends qualifiedin qualified dividends dividends in in College EducationCollege Plans,College Education Education Plans, Plans, filing jointly. The Net Invest- deductions may be filing jointly.filing jointly. The Netexcess The Invest Net ofBIDEN this Invest- amountexcess will excessofBIDEN this ofamountBIDEN this amount will will benefits were retirementadjusted to plans, retirementdeductions etc.businessretirementdeductions plans, may for taxbeplans, mayetc. purposes be etc. ment Income Taxment (NIIT) mentIncome of Income Taxincrease (NIIT) Tax (NIIT) of PLANfrom 23.8%of increase to increase PLANfrom 23.8% PLANfrom to23.8% to ensure corporationsadvantageous paid a advantageousadvantageous 3.8% applies so the3.8% total applies3.8% applies so the43.4%; so total the the total dividends 43.4%; will be43.4%; the dividends the dividends will be will be For tax filers withFor taxFor filers tax withfilers with minimum tax. One may delay harvestingOne mayOne delay may delayharvesting harvesting maximum rate is maximum23.8%maximum rate is rate taxed23.8% is at23.8% ordinary incometaxed attaxed ordinary at ordinary income income taxincome rates of over taxincome ratestaxincome of rates over of over capital losses potentiallycapitalcapital losses losses potentially potentially More on next pageMore onMore next on page next page • The proposal includes a $1,000,000 the $1,000,000$1,000,000 the the planned for the taxplanned yearplanned 2020 for the tofor tax the year tax 2020 year 2020to to long-term capitallong-term gainslong-term capital capital gains gains minimum tax ofa 15%future (allowing year that a anticipatedfuturea future year taxthat year anticipated that anticipated tax tax rate for gains in excessrate for rate gains for gainsin excess in excess for net operatingrates losses will beand higher rates willrates be will higher be higher of this amount willof bethis of amount this amount will be will be certain credits)Consider for selling appreciatedConsiderConsider selling selling appreciated appreciated taxed at 39.6%; thetaxed NIIT taxedat 39.6%; at 39.6%; the NIIT the NIIT corporations withassets a book in the currentassets yearassets in ifthe incurrent the current year if year if of 3.8% will applyof for 3.8% aof will3.8% apply will applyfor a for a income of greatercurrent than rates are currentanticipatedcurrent rates to arerates anticipated are anticipated to to total maximum capitaltotal maximum total maximum capital capital be lower be lowerbe lower gains rate of 43.4%gains gainsrate of rate 43.4% of 43.4% $100mn Use a charitable remainderUse a Usecharitable a trust charitable remainder remainder trust trust for diversificationfor and diversification fortax diversification and tax and tax mitigation of highlymitigation appreciatedmitigation of highly of highly appreciated appreciated assets assetsassets

Federal incomeFederal taxFederal rates income onincome ordinarytax rates tax ratesincome on ordinary on ordinary income income

CURRENT CURRENTCURRENT TRUMP TRUMPTRUMPKEY KEY KEY PLANNING PLANNINGPLANNING TAX LAW TAX LAWTAX LAW RECORD RECORDRECORDCONSIDERATIONSCONSIDERATIONSCONSIDERATIONSOPPORTUNITIESOPPORTUNITIESOPPORTUNITIES The maximum federalThe maximum The maximum federalTax federalbrackets wereTax bracketsTax bracketsThe were lower were current The ordinary lowerThe lowercurrent currentIn ordinary a year ordinary of higher In incomea yearIn a of yearor higher of higher income income or or long-term capitallong-term gainslong-term rate capital is capitalchanged gains gainsrate by is ratethe 2017ischanged changed byincome the by 2017 taxthe rates2017 incomeare income tax rates tax arerateslarge arefinancial transactions,large financiallarge notfinancial transactions, transactions, not not 20%. For 2020 this20%. applies For20%. 2020 to For 2020thisTax applies Cutsthis applies and to Jobs toTax Act, CutsTax andCutsscheduled Jobs and Act,Jobs to expire Act,scheduled or scheduled to expire toonly expire or might or the capitalonly might onlygains might thebe capital the capital gains gainsbe be incomes over $434,550incomesincomes for over $434,550 overwith $434,550 the for top forbracket with thewith topsunset the bracket top as bracket of 12/31/2025; sunsetsunset asif of 12/31/2025;as oftaxed 12/31/2025; at if a higher if taxed rate but taxedat amay higher at a higher rate but rate may but mayContinued single taxpayers andsingle single taxpayers taxpayers andreduced and to 37% reducedreduced tothis 37% would to 37% occur thisthe topwouldthis would occur occurthecause top the qualified top dividendscausecause qualified to bequalified dividends dividends to be to be $488,850 4 for©2021 those$488,850 M&T married Bank$488,850 for Corporation those for thosemarried and married its subsidiaries. Allrate rights would reserved. revertrate to 39.6%; wouldrate would revert revert taxedto 39.6%; toat 39.6%;higher rates;taxed this taxedat higher at higher rates; rates;this this filing jointly. The Netfiling Invest jointly.filing- jointly. The Net The Invest NetBIDEN Invest- - BIDENhowever,BIDEN the qualifiedhowever, however, the qualified thereinforces qualified the needreinforces to reinforcescarefully the need the toneed carefully to carefully ment Income Taxment (NIIT) mentIncome of Income Tax (NIIT) Tax (NIIT) ofPLAN of PLANdividendPLAN rates aredividend not dividend rates areratesconsider not are not the timingconsider andconsider income the timing the timing and income and income 3.8% applies so the3.8% total applies3.8% applies so theThe so total maximumthe total federalThe maximum The scheduledmaximum federal tofederal expirescheduled scheduled to expire torecognition expire and therecognition userecognition of and the and use the of use of tax rate for the highesttax ratetax for rate the for highest the highest available tax deductionsavailableavailable and tax deductions tax deductions and and tax bracket will betax brackettax bracket will be will be credits; the opportunitycredits;credits; isthe to opportunity the opportunity is to is to increased to 39.6%increasedincreased to 39.6% to 39.6% determine how accelerationdeterminedetermine how or acceleration how acceleration or or deferral of these deferralitemsdeferral may of thesebe of theseitems itemsmay be may be NOTE: Currently, qualifiedNOTE: NOTE:Currently, Currently, qualified qualified most advantageousmost advantageousmost advantageous dividends are taxeddividends at dividends are taxed are attaxed at preferred equivalentpreferred preferred equivalent equivalent Contribute fully toContribute all Contribute fully to fully all to all long-term capital gainslong-term long-term capital capital gains gains tax-advantaged accountstax-advantagedtax-advantaged such accounts accounts such such rates; for tax filers withrates; forrates; tax forfilers tax with filers with income over $1,000,000income income over $1,000,000 over $1,000,000 as Health Savingsas Accounts, Healthas Health Savings 529 Savings Accounts, Accounts, 529 529 qualified dividends qualifiedin qualified dividends dividends in in College EducationCollege Plans,College Education Education Plans, Plans, excess of this amountexcess will excessof this ofamount this amount will will retirement plans,retirement etc. retirement plans, plans, etc. etc. increase from 23.8%increase to increase from 23.8% from to23.8% to 43.4%; the dividends43.4%; will be43.4%; the dividends the dividends will be will be taxed at ordinary incometaxed attaxed ordinary at ordinary income income tax rates tax ratestax rates More on next pageMore onMore next on page next page M EMBER OF TH E M & T F A M I L Y M EMBER OFM TEMH EBER M & OFT F TAHM IEL YM & T F A M I L Y

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As always,CURRENT it’s importantCURRENTCURRENT toTRUMP consult withTRUMP TRUMPyourKEY tax advisorsKEY KEY priorPLANNING to makingPLANNING importantPLANNING decisions TAX LAW TAX LAWTAX LAW RECORD RECORDRECORDCONSIDERATIONSCONSIDERATIONSCONSIDERATIONSOPPORTUNITIESOPPORTUNITIESOPPORTUNITIES Theor maximum executing federalThe maximum significantThe maximum federalTax federalbrackets planning wereTax bracketsstrategies.Tax bracketsThe were lower were current The ordinary lowerThe lowercurrent currentIn ordinary a year ordinary of higher In incomea yearIn a of yearor higher of higher income income or or long-term capitallong-term gainslong-term rate capital is capitalchanged gains gainsrate by is ratethe 2017ischanged changed byincome the by 2017 taxthe rates2017 incomeare income tax rates tax arerateslarge arefinancial transactions,large financiallarge notfinancial transactions, transactions, not not 20%. For 2020 this20%. applies For20%. 2020 to For 2020thisTax applies Cutsthis applies and to Jobs toTax Act, CutsTax andCutsscheduled Jobs and Act,Jobs to expire Act,scheduled or scheduled to expire toonly expire or might or the capitalonly might onlygains might thebe capital the capital gains gainsbe be incomes over $434,550incomesincomes for over $434,550 overwith $434,550 the for top forbracket with thewith topsunset the bracket top as bracket of 12/31/2025; sunsetsunset asif of 12/31/2025;as oftaxed 12/31/2025; at if a higher if taxed rate but taxedat amay higher at a higher rate but rate may but may single taxpayers andsingle single taxpayers taxpayers andreduced and to 37% reducedreduced tothis 37% would to 37% occur thisthe topwouldthis would occur occurthecause top the qualified top dividendscausecause qualified to bequalified dividends dividends to be to be $488,850 for those$488,850 married$488,850 for those for thosemarried married rate would revertrate to 39.6%; wouldrate would revert revert taxedto 39.6%; toat 39.6%;higher rates;taxed this taxedat higher at higher rates; rates;this this filing jointly. The Netfiling Invest jointly.filing- jointly. The Net The Invest NetBIDEN Invest- - BIDENhowever,BIDEN the qualifiedhowever, however, the qualified thereinforces qualified the needreinforces to reinforcescarefully the need the toneed carefully to carefully ment Income Taxment (NIIT) mentIncome of Income Tax (NIIT) Tax (NIIT) ofPLAN of PLANdividendPLAN rates aredividend not dividend rates areratesconsider not are not the timingconsider andconsider income the timing the timing and income and income 3.8% applies so the3.8% total applies3.8% applies so theThe so total maximumthe total federalThe maximum The scheduledmaximum federal tofederal expirescheduled scheduled to expire torecognition expire and therecognition userecognition of and the and use the of use of tax rate for the highesttax ratetax for rate the for highest the highest available tax deductionsavailableavailable and tax deductions tax deductions and and tax bracket will betax brackettax bracket will be will be credits; the opportunitycredits;credits; isthe to opportunity the opportunity is to is to increased to 39.6%increasedincreased to 39.6% to 39.6% determine how accelerationdeterminedetermine how or acceleration how acceleration or or deferral of these deferralitemsdeferral may of thesebe of theseitems itemsmay be may be NOTE: Currently, qualifiedNOTE: NOTE:Currently, Currently, qualified qualified most advantageousmost advantageousmost advantageous dividends are taxeddividends at dividends are taxed are attaxed at preferred equivalentpreferred preferred equivalent equivalent Contribute fully toContribute all Contribute fully to fully all to all long-term capital gainslong-term long-term capital capital gains gains tax-advantaged accountstax-advantagedtax-advantaged such accounts accounts such such rates; for tax filers withrates; forrates; tax forfilers tax with filers with income over $1,000,000income income over $1,000,000 over $1,000,000 as Health Savingsas Accounts, Healthas Health Savings 529 Savings Accounts, Accounts, 529 529 qualified dividends qualifiedin qualified dividends dividends in in College EducationCollege Plans,College Education Education Plans, Plans, excess of this amountexcess will excessof this ofamount this amount will will retirement plans,retirement etc. retirement plans, plans, etc. etc. increase from 23.8%increase to increase from 23.8% from to23.8% to 43.4%; the dividends43.4%; will be43.4%; the dividends the dividends will be will be taxed at ordinary incometaxed attaxed ordinary at ordinary income income tax rates tax ratestax rates More on next pageMore onMore next on page next page

Continued

5 ©2021 M&T Bank Corporation and its subsidiaries. All rights reserved. Thomas Kelley, CPA, CFP®, AEP® Cailin MacLean Director of Income Tax Planning Wealth Planning Analyst Wilmington Trust, N.A. Wilmington Trust, N.A.

410.244.3734 410.244.4417 [email protected] [email protected]

As part of the Wilmington Trust Emerald Family Office and As part of the Wilmington Trust Emerald Family Office Advisory team, Tom is responsible for developing customized and Advisory team, Cailin is responsible for supporting and comprehensive wealth transfer and financial management members of the Advanced Financial Planning team with plans for high-net-worth families and business owners throughout the development of customized wealth management and the United States. Tom’s areas of proficiency include estate and financial plans for prominent individuals, families, and business retirement planning, income tax strategies, investment planning, owners throughout the country. She works closely with other and charitable planning. Tom holds a master’s degree in taxation professional and family advisors to analyze financial positions from the University of Baltimore and a bachelor’s degree in and assist in developing plans to help clients achieve future business administration, with a concentration in finance and minor personal and financial goals. She holds a bachelor’s degree in in economics, from Towson University. economics from Hobart and William Smith Colleges.

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