Josh and Hailee have been married for 10 years. Josh had a net worth of
$24,000,000 when he died in 2023. Which of the following scenarios would incur the lowest overall (at Josh’s death and Hailee’s death) estate taxes assuming the property transfers at equal value at the death of both individuals and utilizing 2023 estate tax rates? Assume that portability is not elected. Which of the following scenarios would incur the highest overall (at Josh’s death and Hailee’s death) estate taxes assuming the property transfers at equal value at the death of both individuals and utilizing 2023 estate tax rates? Assume that portability is not elected. For full credit, show your calculations for each scenario and justify your answer.
Josh’s will directs the transfer of $18,000,000 to his two children and the remainder of his assets to his wife, Hailee.
Josh’s will directs that all of his property is transferred to Hailee.
At Josh’s death, specific bequests totaling $3,000,000 are transferred per the direction of the will to individuals other than Hailee. The remainder of the assets are transferred to a trust with the income payable to Hailee for her life and the remainder interest payable to the children at Hailee’s death. Josh’s executor elected to treat this as a QTIP trust.
In his will, Josh funds a trust with $12,920,000 for the benefit of his two children. Hailee will receive an annual income distribution from the trust. All other assets will transfer to Hailee.