Webinar Transcript (3/12/2026): Highlights of the 2026 Heckerling Institute on Estate Planning
Host: Jonathan I. Shenkman, President & Chief Investment Officer of ParkBridge Wealth Management (Contact: jonathan@parkbridgewealth.com)
Panelists: Kevin Matz, Esq., CPA, LL.M. (Taxation), Partner, ArentFox Schiff LLP (Contact:kevin.matz@afslaw.com)
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Jonathan Shenkman: Good morning, and welcome to the Park Bridge Wealth Management Winter Webinar Series. This program is entitled, Highlights of the 2026 Heckerling Institute on Estate Planning. As always, my name is Jonathan Shankman, I'm the President and Chief Investment Officer of Park Bridge Wealth Management.
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Jonathan Shenkman: In that role, I serve in a fiduciary capacity to help my clients achieve their financial objectives. The goal of my programs is to bring professionals together to help them better serve their clients.
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Jonathan Shenkman: This is done by educating attendees on the latest topics in wealth planning, and by encouraging collaboration between a client's attorney, CPA, and financial advisor where appropriate. My practice focuses on working with high net worth families, businesses, and not-for-profits. I manage individual investment portfolios, trust accounts, corporate retirement plans.
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Jonathan Shenkman: And endowments help my clients achieve their financial goals.
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Jonathan Shenkman: In addition to the 20 or so events I run every year, I also do a fair amount of writing on the topics of investing and financial planning, and you can read my work in a variety of periodicals, including Barron, CNBC, Forbes, Kiplinker, The Wall Street Journal, and Trust and Estates Magazine, to name just a few.
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Jonathan Shenkman: You can see all my work on my website at parkbridgewealth.com forward slash articles, or by following me on social media at Jonathan on Money. Additionally, you can check out my weekly podcast, which is also called Jonathan on Money, and you can listen to that on Apple, Spotify, or wherever you get your podcasts. One last item, I recently published my first book, D's for Diversification, The ABCs of Personal Finance, which can now be purchased on Amazon or at jonathanOnMoney.com.
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Jonathan Shenkman: Today, we're privileged to hear from Kevin Matz, a partner of Aaron Fox Schiff, based in New York City. Kevin is a leading advisor to high net worth clients on domestic and international estate and tax planning, estate administration, and related litigation.
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Jonathan Shenkman: A trusted counselor to families and family offices, he combines deep technical expertise with practical judgment. His work spans wealth transfer planning, drafting wills, trusts, gifts, estate income, and GST tax planning, charitable giving, probate, and complex valuations. Kevin also guides
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Jonathan Shenkman: clients on sophisticated strategies such as family-limited partnerships, grants and revocable trusts, cuprates, Ilets, and charitable remainder and lead trusts, as well as private foundations. A nationally recognized speaker, Kevin presents at major conferences on lever transfer techniques and planning for private equity professionals, real estate investors, athletes, and artists. He's also a national authority on Qualified Opportunity Zone funds, and has testified before the U.S. Treasury on
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Jonathan Shenkman: proposed regulations. Today, Kevin will be speaking on highlights of the 2026 Heckerly Institute on Estate Planning, and with that introduction, I'll now turn the program over to Kevin.
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Kevin Matz: Well, thank you so much, Jonathan. Hello, everyone. So, it's funny you mentioned the winter series. At least here in New York, the last couple days have topped 70. I think it was 78 the other day. So, I think we're now going to be into the spring series, but be that as it may, we're going to talk today, for the next hour.
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Kevin Matz: about the recently concluded, or now two months ago, Heckerling Institute on Estate Planning down in Orlando, Florida.
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Kevin Matz: And I'm going to talk initially at a high level, the main themes, so that this way everyone will have a roadmap as to what was covered, and then in the materials, you'll have a lot more. I'm going to then focus, drill down on various items, just to emphasize them, make sure that all the points, again, are covered. Happy to field questions by, you know, afterwards. I don't know if we'll have time between now and 9.30 to field questions. I understand we won't.
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Kevin Matz: But this is to provide, you know, a taste of what happened at Heckerling, and the most important items and ideas that were expressed and exchanged among professionals. Now, before I jump into what was covered, just a word about the Heckerling Institute on Estate Planning.
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Kevin Matz: it is basically the place to be in January of each year. Number one, for those of you who are in… up north, like… like me, in the New York City area, so, it's down in Orlando, Florida, but that's… that's not… that's the only reason. And again, it's… it's down in Orlando, Florida during… during January. But it's a week-long conference that's devoted to… to
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Kevin Matz: Wealth management industry issues, developments,
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Kevin Matz: key legal and tax developments in conjunction with that. It's also a tremendous opportunity to network. So again, it's a week-long conference held at the Orlando World Marriott. There's some other affiliated hotels, too, that could be very easy to either walk to, order shuttle to, with constant shuttle buses throughout the week. But to give you a sense of scope, the total attendance this past year topped 4,400.
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Kevin Matz: And yes, there is also a virtual option, but the total in-person attendance was over 3,200. So think of that. 3,200 trust and state wealth management professionals, attorneys, CPAs, financial planners, insurance professionals.
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Kevin Matz: Family office professionals, all there for the better part of a week.
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Kevin Matz: In close surroundings. It is at a scale unlike any other. If you haven't been there, strongly commended. I've been going each year, with the exception of the COVID years, which were solely virtual, but each year since 2005.
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Kevin Matz: And going back to about, I think it was 2010, 2011, I started doing highlights of heckling, in part for my own knowledge, to make sure that I reinforced what I took away and learned at the conference. And when you… part of the best way to ensure that you learn something is to be able to summarize it and then explain it to others.
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Kevin Matz: So that was about 15, 16 years down the road for it. I've spoken a couple times at Heckling to just a great, great conference, and I'm happy to share this with each of you today. So, what were the key themes with that preface? You know.
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Kevin Matz: You aim for a top 10 list?
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Kevin Matz: I recently, recently, through my firm, put together an article about the top 10 legal challenges facing family offices, high net worth individuals and families as well, here in 2026. For Hackerling.
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Kevin Matz: you know, with some of the other items discussed, I figured, let's… well, I can't exactly do 10 without doing justice to some of the other themes, so here I have a top 14.
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Kevin Matz: So just to go through it, to make sure that everyone has
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Kevin Matz: exposure to what was covered, and then we're going to drill down. So, a lot of time spent on the new tax law. The One Big Beautiful Bill Act.
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Kevin Matz: correct name of it we'll talk about shortly, is actually HR1, because it's part of the budget reconciliation process. The One Big Beautiful Bill Act, as a name was technically stripped out of it, as being quote-unquote extradius, but quite often it's referred to that in that manner, quite often referred to as OBBBA, or OBA.
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Kevin Matz: And also, in Washington, I understand, actually speaking with folks from the IRS and national office there, quite often they refer to it as OB-3, which, for those of you who remember Star Wars, kind of like has a Star Wars-type connotation there.
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Kevin Matz: Obi-Wan Kenobi. So, but OB3. So, if you hear me saying OBA or OB3, that's what I'm referring to. Very important aspect, especially in wealth management, we now have permanent
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Kevin Matz: permanent exemptions. The sky is no longer falling on a sunset to half the levels that we had in potentially in 2025. We now have permanent provisions in effect. $15 million. Talk about that shortly.
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Kevin Matz: Effective as of January 1, 2026,
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Kevin Matz: Bear in mind that, and although this wasn't covered too much in detail at Acurley, bear in mind, if you live in a state such as New York, which is my home state, quite often you have to be concerned about state estate taxes, or states such as New Jersey, state inheritance taxes. So, just because we're dealing with $15 million of exemption doesn't mean you don't have to plan from an estate tax standpoint.
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Kevin Matz: You do, if you happen to… number one, if you happen to be above that, you know, factor in portability. Also, you have to make certain elections for generosity transfer tax or GSD tax purposes, but always bear in mind your home state. New York only has a $7,350,000 exemption. Here in the year 2026, it has this very, in lack of a better word, nasty
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Kevin Matz: feature of its tax law called the New York Estate Tax Cliff, that says we're going to give you a credit corresponding to that. If you're slightly above that.
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Kevin Matz: We're going to take it away on a hyper-accelerated basis, so that if you're 5% above that, a little over $7.7 million, you're going to be taxed from $1, and that actually produces a…
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Kevin Matz: in lack of a better word, confiscatory marginal tax rate, in some cases, of over 200%.
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Kevin Matz: more on… more on that, perhaps, another day, but that's something to bear in mind. Always gotta consider state death taxes, too. Another item addressed, Trump Accounts, Section 529 plan expansion. Next, big, big theme.
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Kevin Matz: at Heckerling this year, both in terms of substantive law developments, and also in terms of practical challenges in representing clients and ethical considerations. Marital planning, including marital trust planning. What if you have a Q-tip marital trust that's been set up,
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Kevin Matz: you get the estate tax barrel deduction. One spouse dies. But what if there's a desire
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Kevin Matz: of the surviving spouse, together, perhaps, with children, to get together, do more planning. You gotta watch out for the section of the Internal Revenue Code called Section… or, specifically Section 2519.
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Kevin Matz: Which provides that if there is a deemed disposition of an income interest, the entire remainder
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Kevin Matz: whatever that is, could be… it could be a small amount, it could be $100 million, is a deemed gift that's made. Now, there have been various cases over the past
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Kevin Matz: 18 months, 2 years that have addressed this, the Annenberg-McDoul case in particular. What about if the children give up their remainder interest? Are they deemed to be making a gift to the surviving spouse? We'll talk about that shortly. That got a lot of attention. But then the whole issue of marital trust planning and some of the ethical issues in representing both spouses, that got a tremendous amount of attention, in part
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Kevin Matz: sparked from a New York
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Kevin Matz: Not a trust and estates case, not a tax case, but rather a family court case, or rather a family law, matrimonial law case, CS versus RH. CS versus RH, and yes, the initials, abbreviations are used to protect the innocent here.
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Kevin Matz: That got a lot of attention. What happens if marital assets are used for the planning, and everything's going well.
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Kevin Matz: Until they're not.
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Kevin Matz: In this particular case, because there's a divorce.
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Kevin Matz: And what happened to the estate planner has represented both spouses, and then the one spouse, in this particular case, the wife, says, I thought this was just a tax shelter. I didn't realize that I would no longer have assets, access to these assets here, including
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Kevin Matz: By virtue of being able to have access through rental agreements or otherwise.
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Kevin Matz: Do these assets get considered for marital estate purposes, marital asset purposes, in the event of divorce? The answer in CS versus RH, we'll talk about that got a tremendous amount of attention in the peckling, is yes, at least in New York.
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Kevin Matz: they do count under the particular facts that are set forth. And as we'll talk about, the facts are rather extreme there, but it is a very cautionary note.
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Kevin Matz: Along those lines, terrific programs, collaborative estate planning advisory team, navigating issues, pertaining to attorney-client privilege. Let's say it's not just attorneys, attorneys working with CPAs, other wealth management professionals, financial planners, trust companies. What do they speak about, speak to each other with a client there? Do you potentially lose attorney-client privilege?
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Kevin Matz: What are the best
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Kevin Matz: best practices to preserve attorney-client privilege, to preserve confidentiality, and when do you maybe have to set up dividing lines? That got a lot of attention, too. Some of the discussion was, well, in some cases, depending on the sensitivity of the discussion, if there's information, confidential information being conveyed to an attorney for purposes of advice, so as to invoke the attorney-client privilege.
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Kevin Matz: In that case, maybe the other professionals in the team need to step out.
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Kevin Matz: From the meeting, be it in person, or be it via Zoom or Teams.
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Kevin Matz: or other virtual platform. Maybe you need to have a so-called COVAL agreement that addresses it, which says that that other professional quite often works with the accountant, CPA, is basically serving as an agent to assist the attorney to, in some ways, effectively translate difficult financial facts so the attorney can render full, fulsome and comprehensive advice to the client.
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Kevin Matz: That could work, but you have to be very mindful, because otherwise there's a risk of loss of attorney-client privilege. Terrific program, special needs planning, Atara and Pleat.
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Kevin Matz: presented on that. She's the current, chair of the Trust and States Law Section, New York State Bar Association. Just some eye-opening facts concerning how, basically, as a practical matter.
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Kevin Matz: Family members serve as a safety net, and that's not really recognized,
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Kevin Matz: Quite often by the government, also in terms of economic analysis that's related to it, but if you are doing special needs planning, and you have a beneficiary who stands to inherit, watch out, because that could be considered a resource that could disqualify that benefit… that beneficiary who has disabilities, who has special needs, from eligibility for government resources.
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Kevin Matz: Splitting, splicing, and stacking strategies to add octane to truss structures. Wonderful presentation, Diana Zadel, Jonathan Blotbacher, my partner.
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Kevin Matz: Todd Agatabanich talked about sophisticated estate planning techniques. We'll not… we'll cover some of that in context, including the LCAN case. We'll talk about that shortly. There was some discussion, too, about cases the la… maybe about 18 months ago now, a state of fields case. You gotta watch out whenever you're planning with family limited partnerships. Simply the ability to liquidate, participate in liquidation decisions.
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Kevin Matz: As a limited partner, to join together.
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Kevin Matz: reiterates a holding of the State of Powell case, which was a 2017 tax court case. That is an estate tax triggered under Section 2036A2.
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Kevin Matz: Which means unless you're able to override that by virtue of the bona fide sale exception, to the application of Section 2036 of the Family Limited Partnership or Family Limited Liability Company posture, could result in a state tax inclusion of all the assets, without any discounts, lack control, lack of marketability, unless one say, well, nothing ventured, nothing gained, you gotta try, right?
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Kevin Matz: Well, not necessarily, you know? So, as I've written about, going back a number of years, if you have a, if you're trying to have a reduced to zero marital
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Kevin Matz: marital trust planning formula. You actually can frustrate that, because you cannot have phantom assets passed to a marital reduction trust that could actually accelerate estate tax to the first spouse's death. In addition, what you had in fields is that you had the IRS say, come on.
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Kevin Matz: We think that you… that you should have… you, the executor, should have known of Section 2036, or consulted counsel as to that, and are you thinking that you could make $6.5 million disappear by transfers to an FLP about a little… about a month before the decedent died? That was likely too good to be true. No reasonable cause exception. We're gonna whack you with a 20% accuracy-related penalty.
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Kevin Matz: and the tax court upheld that. So, again, you could actually be worse off than doing nothing with FOP planning, so watch out. Huffman case, again, that's really more 2024, but just a note there that, you gotta watch out for another
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Kevin Matz: technical provisions to the Remedy Code, Section 2703. Whenever you have interfamily agreements, they can buy-sell agreements. We had the Connelly case from the year before, Supreme Court case. Hoffman involved an option agreement to basically buy about $31 million worth of company stock.
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Kevin Matz: For $5 million, pursuant to the option.
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Kevin Matz: It was an interfamily agreement. The court evaluated, do you run the Garland? Are the potential exceptions under Section 2703B in the Revenue Code? It was not met on an evidentiary matter. It's being able to show that the agreement was comparable to other agreements between parties who were unrelated at arm's length, and therefore, instead of having a $5 million
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Kevin Matz: valuation, for the, for the closely held business interest, pursuant to the option agreement. Instead, it was at fair market value, with the option agreement disregarded. That was at $31.3 million. Ouch, a big tax hit, to the taxpayer there. Turning it around, though, a favorable tax court result,
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Kevin Matz: The estate of Barbara Galli case versus Commissioner, there, it says that if you do things right with a promissory note, and you have a loan, and you dot the T's… I'm sorry, you cross the T's, and you dot the I's, and you have a promissory note that actually is rendered, you pay interest in the promissory note according to its terms, you have
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Kevin Matz: You actually have the payments reflected in bank records. The interest is at the AFR, which might have been actually slightly below market, but it was still at the safe harbor of the applicable federal rate. In effect, even with a balloon, no, with interest payments, they were timely made before mom died. That was held to be respected.
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Kevin Matz: by the court. Why? Because they did it right.
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Kevin Matz: They crossed the T's and dotted the I's. So that's something, that, that is not so much a cautionary tale, but it is a… it is something to point to as to if you do it… if you do it correctly.
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Kevin Matz: you follow… you follow the terms of the loan, you have interest paid timely, you have a… you have a reasonably well-drafted promissory note, you have an AFR interest rate.
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Kevin Matz: that will be respected as a loan, and the IRS has tried to say, well, you know.
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Kevin Matz: CETA died here. There was an argument that was made in connection with the estate tax return that there should be a discount applied to the promissory note from $2.3 million down to about $1.6 million because interest rates went up compared to the AFR, and the IRS attempted to argue that, therefore, this should be treated as a gift and not a loan, but the tax court had… would not tolerate that.
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Kevin Matz: is that everything was done right here. There may have been a change in interest rates over the course of time, but the taxpayer and the both parties
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Kevin Matz: respected the terms of the loan, they honored it, and therefore, we, the court, are going to respect it as debt, as a loan, and will not, give any credence to the IRS's argument that instead should be treated as a gift.
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Kevin Matz: A case that got a lot of attention.
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Kevin Matz: Item 12 here, the LCAN case. And this is a case, you know, there is no reported decision right now. It is an ongoing litigation. The government… I'm sorry, the taxpayer just filed their… their reply brief on this last week.
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Kevin Matz: This involves a grant-to-retained annuity trust. We'll talk about this, shortly, but, basically about… or multiple grantor-retained annuity trusts, that were funded to the tune of about $1.5 billion, not million, but billion with a B.
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Kevin Matz: And, the, there were swaps.
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Kevin Matz: in, exercising the power substitution, which is a grant or trust trigger that was built into the grant. It was a very well-drawn grant, and by virtue of the swaps in, we're actually, with a promissory note of the grantor, it then came time for the annuity payment to be made by the grant trustee.
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Kevin Matz: to the grantor.
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Kevin Matz: Gotta, gotta pay out what you have, so…
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Kevin Matz: What did the grant trustee pay? Paid the grantor's promissory note that was swapped in. The IRS said that that's too clever.
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Kevin Matz: we think that you've actually blown the terms of a grant, so don't have a qualified interest in a grant, and you think you had a $1.5 billion transfer, getting back a roughly $1.5 billion annuity? Think again. We think that you have
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Kevin Matz: In non-qualified interest, you're going to have a $1.5 billion gift.
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Kevin Matz: And, there was actually gifts playing between spouses, so… so the spouse who did not make the gift, you know, she got tagged with about… with, over $300 million right there. And on top of that, they said, again, being asserted quite heavily by the IRS these days.
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Kevin Matz: We're gonna attack on to that a 20% accuracy-related penalty for negligence and disregard of the rules.
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Kevin Matz: So, again, that is right now being litigated. The primary argument by the taxpayer is that if you look at the regulations.
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Kevin Matz: which are the regulations that the IRS is bound by, it does not prohibit the return of the grantor's own promissory note to the grantor.
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Kevin Matz: What it says, it prohibits financing arrangements and prohibits the grant trustee from issuing its own
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Kevin Matz: promissory note. Not returning the grantor's promissory note, but issuing its own promissory note to fund… to fund the annuity amount. Essentially, the IRS, that's taxpayer's argument. The IRS is saying that, you know, by doing it this way, you effectively had a de facto commutation, which is prohibited under the regulations. Taxpayers' further argument is regulations don't accord with the statute.
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Kevin Matz: And therefore, under the Loper-Bright Supreme Court Case 2024, is not a best reading of the 2702B statute, and therefore should be disregarded. So stay tuned, that is currently in litigation. Couple other items that are addressed here. Qualified small business stock. There was a terrific presentation by Paul Lee.
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Kevin Matz: On that at Heckerling, Section 1202. Section 1202 has been around since 1993, but it really got hypercharged when the corporate rate, because you need to have domestic C corporations, involved here, when the corporate tax rate got lowered to 21% in the Tax Cuts and Jobs Act of, 20…
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Kevin Matz: 17. Here, with OB3, we now have a situation that there's a further enhancement in the benefits of the qualified small business stock. Basically, it says that if you meet certain criteria for a domestic corporation, that's a C corporation.
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Kevin Matz: And you have stock that's been… that's been issued not through a secondary market or subsequent sale, unless it's a gift that's truly… that's truly not a sale, or someone's inherited by… by death.
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Kevin Matz: But if, if, if you have issued stock.
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Kevin Matz: Directly from the issuer, or someone to step into shoes of the transferee of the issued stock.
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Kevin Matz: You're gonna have a situation where, that person can exclude substantial capital gains, and the amount of capital gains that could be excluded are the greater of, a per-taxpayer limitation, which had been $10 million, is now up to $15 million.
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Kevin Matz: Or, if greater than that, 10 times the basis. And you could have stock here that used to be limitations of $50 million, it's now raised to $75 million. You could potentially have qualified small business stock, QSBS,
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Kevin Matz: For assets, for stock where the total basis is up to $750 billion.
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Kevin Matz: And then there's lots of… there's techniques to further enhance that, stacking techniques that could be utilized via gifts, including to non-grantor trusts that are set for taxpayers. So that… that… that has been probably one of the greatest areas that I've been contacted about and called about here in 2026, and that got a great deal of attention at Heckling. The other item that I've been getting a lot of calls on here in 2026
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Kevin Matz: It was touched on a little bit at the very end by Clary Redd, in his wrap-up program, at, at HackerLink, but it is something that is
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Kevin Matz: very critical for those of our clients who have invested in Qualified Opportunity Zone funds going back to the last several years is that subject, item 14, Qualified Opportunity Zone funds. We now have a tranche 2 for Qualified Opportunity Zone funds that kicks in as of January 1, 2027.
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Kevin Matz: very importantly, Tranche 1, under the Tax Cuts and Jobs Act, ends…
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Kevin Matz: on December 31, 2026, and the whole notion here is to basically to spur investment in economically distressed communities, defined as Qualified Opportunity Zone… Qualified Opportunity Zones, or OZs.
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Kevin Matz: Congress decided we're gonna allow this new vehicle statute to be created, Qualified Opportunity Zone funds, which could then be funded with capital gains, it has to just be capital gains, that are then,
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Kevin Matz: within 6 months of a capital gain, occurring, or deemed to occur, there's certain elections that could be made, that my materials address, you can defer the gain, potentially to an outside date of December 31, 2026, possibly with a 5-year hold or 7-year hold, make up to 10% or 15%, respectively, of that gain disappear.
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Kevin Matz: And, then also be able to, with a 10-year hold, have any subsequent appreciation, avoid tax whatsoever. The key item that I mentioned here, in addition to the Tranche 2, which extends the rules and changes some of the rules, is
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Kevin Matz: the date of December 31, 2026. Today is March 12, 2026, so that is… that is less than 10 months away now, and that is when all the deferred capital gains become due, less the basis adjustments. One thing I will note.
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Kevin Matz: and I've written quite a bit about this, but under the terms of the final regulations that came out in 2020 from the U.S. Department of Treasury and the IRS, there's actually a lower-of rule, and this is also in the statute, too, a lower-of rule that applies. It's a lower of the deferred gain on December 31, 2026,
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Kevin Matz: or the fair market value of the Qualified Opportunity Zone Fund interest as of that date, which means that if the values have gone down over the course of time.
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Kevin Matz: the benefit of an appraisal, the amount of the task could be potentially substantially reduced. One thing I would note, and this was made clear by the final regulations that came out in 2020, back when I spoke as part of a panel on Heckerling in 2020, I actually confirmed this with a government official who was involved with drafting it, because it seemed to be the imported language, is a fraction build-in. Question I get a lot of… quite often is, do you get any discounts?
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Kevin Matz: lack control, lack of marketability associated with that, and the clear answer, at least by virtue of the fraction that's in the regulations that was confirmed to me by a Treasury official who was involved in
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Kevin Matz: in drafting it is no such discount would be available. Whoops, absolutely just hit my computer. I'm still here, though.
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Kevin Matz: That's what happens when I raise my hand. But let's talk a… drill down on some various items, okay, during the next half hour or so, 32 minutes.
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Kevin Matz: So, again, formal title, yeah, it's referred to as the One Big Beautiful Bill Act.
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Kevin Matz: OBA, O-B-B-B-A, or OB3, but if you want to get technical, by virtue of the budget reconciliation process, and with the name being stripped out as quote-unquote extraneous.
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Kevin Matz: It is instead, the formal title is H.R. 1, an act to provide for reconciliation pursuant to Title II of H. ConRes 14.
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Kevin Matz: So, just, just so you know, what are the various items addressed by OB3?
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Kevin Matz: I've addressed… I've already touched on some of these items, but just to drill down a little bit.
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Kevin Matz: So we now have a quote-unquote permanent $15 million estate gift for generators could be transfer tax exemption, beginning here in 2026. That is going to be indexed from year to year. What I mean by permanent, you no longer have an expiration date. Under the Tax Cuts and Jobs Act.
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Kevin Matz: yet a situation where the quote-unquote temporarily doubled exemption was scheduled to sunset to half that level after December 31, 2025. By virtue of OB3, the expiration date got removed, and then we had a further bump up
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Kevin Matz: from what otherwise would have been $14.4 million, half of that would be only $7.2, to now 15 million. What that means is we no longer find ourselves in the posture of
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Kevin Matz: for those clients who are above the exemption levels of use it or lose it. Under the regulations that had come out a number of years ago, final regulations, Treasury and the IRS made clear that if you made
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Kevin Matz: if you made, gifts, used up your exemption, there wouldn't be any, clawback, so long as you were in a situation that was considered abusive or had a string provision, think Section 2036 apply. And therefore, much of planning involved, planning was, especially for married couples, spousal lifetime access trust, SLATs. So this way, people would make gifts.
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Kevin Matz: still through a spouse, have quote-unquote backdoor access, so at least the spouse could enjoy the benefits, but lock in the exemption, which would otherwise be lost if there were to be a reversion to half that level due to the expiration after December 31, 2025.
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Kevin Matz: no longer have to worry about that. You could basically take that from one corner of your brain and say, I don't have to worry about anything else except a historical footnote. We now have a permanent exemption. Now, what does permanent mean? Permanent means, well, there's no expiration date anymore in the statute.
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Kevin Matz: it is possible it could be changed, of course, by a subsequent Congress. I don't think anything's going to happen over the course of the next 3 years.
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Kevin Matz: But you just never know down the road. So that's something to bear in mind, but at least there is no longer an expiration date. It is the mantra of use it or lose it, which was so pronounced, at least prior to the November election in 2024,
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Kevin Matz: is no longer applicable. Some of the other changes brought about by, by, by OB3, we now have a
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Kevin Matz: $40,000 assault deductions, state and local taxes.
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Kevin Matz: Subject to phase-out, though, once you get above $500,000 of the applicable threshold amount, that's increased from $10,000. After that phase-out, it gets back to $10,000. Importantly, the pass-through entity tax credit is preserved.
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Kevin Matz: People say, well, what's so news about that? That actually was not so clear that that result would follow. Earlier versions
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Kevin Matz: of OB3, actually called for an elimination of the pass-through energy tax credit, but that was, left in the, on the, shopping, I guess the chopping floor, as they say.
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Kevin Matz: And didn't make its way to the final bill. Section 199A, pass-through deduction for qualified business income, not so much a… there wasn't a technical change there, but the, the phase-out limits where you get subject to phase-out were increased significantly under OB3, so that's something to bear in mind, too.
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Kevin Matz: Something we'll talk about shortly. Trump accounts and Section 529 plan enhancements. Trump accounts have now come in. We actually just had regulations that
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Kevin Matz: proposed regulations that came out concerning the pilot program. Discuss that shortly. One item that got a fair amount of attention at Hackerling.
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Kevin Matz: And it's also through American Council of Trust and States Council, ACTEC has got a great deal of attention as well.
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Kevin Matz: is we now have a permit suspension of miscellaneous itemized deductions, so they aren't just suspended as being deductible, they are just non-deductible. But then, on top of that, if you have itemized deductions.
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Kevin Matz: There is now a limitation
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Kevin Matz: of 2 37ths. And what do I mean by that, and 2 37ths? Why not two 40ths, or 2 50ths, or something like that, or two 100ths? Well, think in terms of the top tax rates that apply. Top tax rate, putting aside the net investment income tax, or self-employment tax, top tax rate, ordinary income is 37%.
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Kevin Matz: what… Congress has said that even though the top tax rate is 37%, if you have an itemized deduction.
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Kevin Matz: The maximum deduction benefit you're going to get from it is going to be capped at 35%.
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Kevin Matz: And therefore, 37 minus 35 is 2, 2 divided by the… by 37, that's how you get 2 37ths. Now, how does this affect the world of many of the folks who are listening to this, to this webinar series today? Well, it affects
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Kevin Matz: The way the statute appears, it's not so clear what the result is.
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Kevin Matz: concerning the distribution deductions for trusts and estates, and then also the Section 642C deduction for distributions from trusts and estates to charities. There is a…
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Kevin Matz: fair argument to be had, just by reading the statute, that those deductions are itemized deductions. And because they're itemized deductions, and because there was an elimination regarding the distribution deductions for trusts and estates.
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Kevin Matz: for being itemized deductions and subject to limitations under Section 68… 68E, which was repealed, the concern is, and based upon language in the Senate Finance Committee report,
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Kevin Matz: there is… is concern that… that deductions for distributions, effectively allocations, to beneficiaries from trust and estates, are subject to this floor. There's also concern, notwithstanding the language of 642C that talks about it being without limitation, there is a fair reading
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Kevin Matz: that charitable deductions for what gross income distributed out from trusts and estates, charitable beneficiaries are themselves subject to this limitation. Now, what does that mean?
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Kevin Matz: That means, like, let's say, and this applies whenever you're in the top tax bracket, like, here in the year 2026, you hit the top tax bracket for trust and estates at a very low level. It was the case in prior years, where it's now at $16,000, not $500,000 or $600,000, but $16,000.
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Kevin Matz: So, everything above that's a 37% bracket. So, let's say you had a million dollars above that, and let's say you're distributing out to beneficiaries.
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Kevin Matz: You'll have $370,000 and a million dollars above once you get into the 37% rate of tax. However, the trust and estate will only get
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Kevin Matz: if this, in fact, is the case, and again, there's a fair reading that's the case, although I will tell you that clarification's been sought by some organizations, including American College Trust and States Council, as to this, with some very good arguments as to why this should not be happening, but at least we're requesting clarification, both from Congress and then also from Treasury slash IRS.
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Kevin Matz: That if you have $370,000 of income, you only get a tax benefit deduction of $350,000. So a trust or a state, which, think of, in terms of the nature of the conduit taxation.
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Kevin Matz: The purpose here is you tax either the trust or estate, or, by virtue of the mechanism, of the distributed distribution deduction for DNI, distributed net income, distributed out to beneficiaries, or you tax a beneficiary.
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Kevin Matz: you're not supposed to tax both. It's one or the other. However, if you have $370,000 of tax benefits at the, trusted or state level, but you only get a $350,000 deduction for it, you effectively have
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Kevin Matz: double taxation, even though the whole purpose of Subchapter J and the Revenue Code is to avoid double taxation.
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Kevin Matz: Does that make sense? Doesn't make much sense, but that is…
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Kevin Matz: That seems to be the implication of the written word by Congress. I can tell you organizations, including American College of Trust, States Council, I believe also the AICPA has now submitted on this, have said, hold on a second.
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Kevin Matz: is…
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Kevin Matz: did you really intend this Congress to do this? You know, maybe this warrants a technical correction, at least to clarify. And then what about with charities? Well, it's even a worse-case scenario with charities, because charities are designed to not pay any tax. However, you're… even though you could… the goal for the trust or estate, based upon the language of the trust instrument or the will.
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Kevin Matz: could be to zero out. Nevertheless, you're subject to potential
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Kevin Matz: taxation here on income that is ultimately going to charity. Does that make policy sense, ladies and gentlemen? I submit it doesn't, ACTEC submits it doesn't, AICPA agrees as well, but stay tuned, that this will be
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Kevin Matz: Hopefully, we'll get favorable corrective action.
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Kevin Matz: Either by Congress, or by Treasury or IRS over the course of time.
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Kevin Matz: Addressing this.
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Kevin Matz: Other items addressed for charitable deductions, you now have, different rules for itemizers and non-itemizers. There's now a 0.5% floor for itemizers, non-itemizers, non-itemizers, even without, without itemized deductions, you now get a, potential marriage filing jointly $2,000 charitable deduction, so that, that's changed. Note here on excise taxes and colleges and universities.
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Kevin Matz: Under the new tax law, not on private foundations, no change there. And a couple items I've already mentioned. Qualified small business stock expansion, I talked about that, and also some… we have this new tranche rule for Qualified Opportunity Zone funds.
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Kevin Matz: Again, regarding federal, state, gift, and GSD tax provisions, we now have permanence! But permanence really means not subject to a sunset or expiration date that's hardwired into the law.
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Kevin Matz: What this means is a practical matter, though. The exemption level's so high.
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Kevin Matz: That doesn't mean that clients don't have to worry about tax planning, aside from
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Kevin Matz: dispositions being exactly where they want it to be when they're no longer… no longer living. You gotta think in terms of income tax planning. And sometimes, if you're not worried about estate… about estate taxes, including state estate taxes, sometimes you're gonna want estate tax inclusion. Why? Because if you have estate tax inclusion, you get a step up in basis to fair market value.
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Kevin Matz: which could wipe out any built-in capital gains tax that applies, or for depreciable assets, in terms of real estate, could basically restart the clock at a much, much higher level on when you could depreciate assets. So income tax planning.
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Kevin Matz: are… become even further heightened in importance because of this. Now, I talked about state… New York State. Jump over to Trump accounts. Now, Trump accounts are new…
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Kevin Matz: Creatures of statute under new Section 530 cap A of the law.
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Kevin Matz: It allows for aggregate contributions for up to $5,000 each year. It's going to be indexed for inflation. That's eligible to be made by parents, relatives, taxable entities, nonprofits, and governmental entities. This is only for persons who are under the age 18.
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Kevin Matz: under the age of 18. If you're over 18, you could not… you could contribute to a Trump account, but you cannot be a beneficiary of it.
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Kevin Matz: And the notion here is basically a built-in savings account where there cannot be any distributions made before age 18.
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Kevin Matz: These would be, managed by banks or institutions, and would generally have to be invested in stock index funds or other diversified investments. In addition, there were just proposed regulations that came out last week on this, from Treasury and the IRS. There's now a… there's also a one-time governmental credit of $1,000 that will be provided to certain individuals born in the years 2025 through 2028 who
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Kevin Matz: who are U.S. citizens.
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Kevin Matz: So what issues are presented in the trusted estates world? Well, we have a contribution that's being made to an account that cannot be accessed by the account beneficiary until they age… until they attain age 18.
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Kevin Matz: is that a present interest in property? Well, it doesn't meet the definition of the present interest in property, because it's not accessible until someone who's under 18 down the road turns 18. Now.
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Kevin Matz: very interestingly, with Section 529, not 538, but 529 plans, think in terms of college tuition and related cost plans that are set up, set up by the various states under a federal enabling statute.
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Kevin Matz: That addressed it, actually, under a technical provision under Section 529, that hits this head-on and states that for purposes of Chapter 12 of the Internal Revenue Code, dealing with gifts.
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Kevin Matz: And Chapter 13, dealing with the generosity Transfer Tax.
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Kevin Matz: Any contribution into a 529 plan
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Kevin Matz: shall, per the statute, that's actually 529C2A1 of the Section 529 statute, any contribution will be deemed to be a completed gift to property that is a present interest in property, not a future interest, and therefore qualify for the gift tax annual exclusion.
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Kevin Matz: Unfortunately, that language was not present in the enacting statute for Trump accounts. So I can tell you, American College Trust and States Council has had two separate letters, two that's gone to, Congress.
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Kevin Matz: Addressing this, also the Treasury and the IRS, I consider the Treasury and the IRS is… has taken the position, we'd love to help you, but this is something that Congress has to deal with, because, you know, you look at 529, they had a statutory
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Kevin Matz: language that affected that, it would be, you know, we don't have that here, so hopefully there will be a corrective fix at some point. Trump accounts are scheduled to go live by July 1.
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Kevin Matz: So hopefully we'll have a corrective action taken by Congress to clarify the contributions to it, once we hit July 1, will in fact qualify the gift tax annual exclusion. What happens if they don't? It means that if someone makes, say, a $100 contribution to a Trump account, technically, they have to file a gift tax return.
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Kevin Matz: To report that, and if it's too…
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Kevin Matz: If it's to someone who's two generations down, think in terms of a grandchild, or if unrelated, more than 37 and a half years younger, you then have to also report that as a generous keeping… as a skip for generous keeping transfer tax purposes. And if someone has used up all their lifetime exemption.
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Kevin Matz: for gift or GST tax purposes, they will actually have to pay gift tax at the rate of 40% on that.
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Kevin Matz: That can't be what Congress intended. Unfortunately, the language seems to provide for that, but hopefully, hopefully, that will be corrected before we go live on Trump accounts on July 1. 529 plans?
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Kevin Matz: there's disgusted heckling, there's been an expansion of it, that basically is broadened. An item that I can tell you the AICPA was very much involved with the advocacy on concerns qualified post-secondary credentialing expenses that are added to include tax-exempt distributions, that go to fund
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Kevin Matz: CPE credit for CPAs, or CLE credit for attorneys, or CE credit for financial planners. You can now have that set up. The one thing, cautionary note.
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Kevin Matz: Even though that's… that's allowed.
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Kevin Matz: and you're not going to have a non-qualified distribution that is subject to income tax and subject, potentially, to an excise tax at the federal level. Well, look at your state rules.
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Kevin Matz: look at your state rules, because not every state plan automatically conforms to federal, and you… if you were to say, let's have a distribution here that's… that under OB3 works, you may be subject to state income tax, by virtue of that, so you have to watch out.
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Kevin Matz: watch out. Again, main… a major, major theme discussed, marital trust planning, you had a… you had a troika of cases, the Annenberg case, you had…
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Kevin Matz: also the McDougal case, and then beyond that, you had the Griffin case. For the first two of the cases I mentioned, Adam and McDougal, we're dealing with a saga of a qualified terminable interest marital deduction trust.
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Kevin Matz: which, again, is a trust that has to… that… for which an election is made on… on the estate tax return. It could also be set up via gifts, by the way, but in this context, it was… it was in the context of the estate.
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Kevin Matz: The property, basically, the surviving spouse has to have a qualifying income interest for life, meaning the right to all the income, and no person can have the power to appoint any of the property to anyone other than the surviving spouse. Okay? So what's the issue there?
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Kevin Matz: Well, the issue there is what the surviving spouse expects to live for a very long time, and those are the assets that are best suited in the view of the advisors to the surviving spouse, and maybe the kids, or further
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Kevin Matz: For the remainder of beneficiaries for down the road, for further estate planning.
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Kevin Matz: How do we proceed there? How do we access it? Well, if you have broad discretionary distribution authority given to the, to maybe an independent trustee to make distributions besides income, besides health, education-based support, but discretionary distributions out to the surviving spouse, that would be one way.
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Kevin Matz: But what if that's not conferred under the terms of the trust instrument? And also, what if perhaps the independent trustee maybe gets nervous?
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Kevin Matz: about making distributions out to a surviving spouse, perhaps the… perhaps the remainder of what's in there, and says that I want to get… I want to make sure that the kids don't sue me, so I'm going to want them to consent to this. Well, consequence here was…
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Kevin Matz: let's get the kids together with the surviving spouse, and make the distributions. And the IRS had two separate arguments. First argument, asserted in both cases, Annenberg and McDougal, was, well, there should be a deemed gift by…
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Kevin Matz: surviving spouse here, because there was further planning that was done down the road, that basically then was surviving spouse, after the termination of the trust in the surviving spouse's favor, Annenberg was going to court, McDougal was a non-judicial settlement agreement without going to court, further planning, is there a gift by the surviving spouse?
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Kevin Matz: And the court… task court in both cases said, no, there's no gift by the surviving spouse. Surviving spouse, if anything, is making a gift to her… himself or herself.
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Kevin Matz: You can't make a gift to oneself. Therefore, No gift.
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Kevin Matz: But the second…
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Kevin Matz: argument that was made by the service, by the IRS, wasn't made in the Annenberg case, but it was made in the McDougal case, was, okay, the kids had the right to remainder interest.
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Kevin Matz: And then there might be subsequent transactions in which they get benefits, but if we just freeze frame, and you look at the termination, where they have a remainder interest.
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Kevin Matz: And all… one day one, and day two, they have nothing. There may be subsequent sales to… to…
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Kevin Matz: intentionally defended grant or trust in their favor, may be part of a plan, but it just frees it at that point in time, haven't the kids made a gift to the surviving spouse?
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Kevin Matz: And that wasn't raised in the Annenberg case, but it was raised in McDougal, and McDougal, the court said yes.
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Kevin Matz: There was, in fact, we do, in fact, regard there to have been a gift.
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Kevin Matz: by the children, holding the remainder interest, where they consented to the termination of the Q-TIP trust in favor of the surviving spouse.
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Kevin Matz: So then, the $100 million question.
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Kevin Matz: literally, because that's what the IRS is asserting, is, okay, there's a gift by the kids, What's its value?
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Kevin Matz: The IRS is saying, well, it's a $100 million trust, we think it's about $100 million a gift.
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Kevin Matz: Pay up $40 billion of gift tax.
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Kevin Matz: Taxpayer was on the view, well, hold on a second. You know, they're… how do you know that these kids are going to survive their surviving, their, you know, in this particular case, their father?
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Kevin Matz: And, and, that, you know, why are you assuming that it's, it's such a high value?
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Kevin Matz: there could be… it could well be that over the course of time, everything gets… gets spent, you know, or would have been spent in the Q-Tip trust prior to the termination. So, maybe it should be a, yeah, some value, but a speculative value that's discounted very heavily and much, much lower number.
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Kevin Matz: So that is right now, presently, being litigated in the tax court.
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Kevin Matz: An important theme discussed in heckling was, you know, the IRS is getting much more assertive in these contexts, especially when it comes to the question of consenting to a transfer. You had an IRS litigation position from the National Office and Chief Counsel Advice 2023-52018.
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Kevin Matz: Where they said, if you consent to a gift.
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Kevin Matz: or a consent to a transfer, you're potentially deemed as making a gift right then and there. And then it's a question to be litigated as to how much is involved. So this is an area that the IRS has been increasingly focused on.
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Kevin Matz: One point in the Griffin case, Griffin case illustrates that if you don't… if you don't make a Q-TIP election and don't have the requirements for Q-Tip trust.
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Kevin Matz: all income paid annually to surviving spouse, and no one could be a beneficiary of the trust other than the surviving spouse, and very, very importantly, wasn't done in the Griffin case, you have to make the Q-tip election on the estate tax return, or if it happens to be an intervivos gift on the gift tax return, that wasn't done here, disqualification. But there was a potential saving grace in a smaller trust
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Kevin Matz: concerning a so-called estate barrel deduction trust, where at the end of the day, everything got paid to the surviving spouse's estate, and that was held to be a saving… saving grace. On this subject.
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Kevin Matz: you know, spends a little bit more time, because I've covered
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Kevin Matz: a number of items already, but there was the case CS versus RH.
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Kevin Matz: That, that, that happened. And this, this tied in with the prominent themes of conflicts and joint representation.
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Kevin Matz: Some great discussions, Bruce Stone, Stephanie Loomis-Price, Jim Daugherty.
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Kevin Matz: Laura Woven all spoke about issues pertaining to, let's say you establish a spousal lifetime access trust, a trust as to which one of the beneficiaries, doesn't have to be an exclusive current beneficiary, but one of the beneficiaries is a spouse.
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Kevin Matz: And everything seems to be going well.
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Kevin Matz: But there are two ways that marriages can end, right? They could end by virtue of death.
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Kevin Matz: Someone… a spouse dies?
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Kevin Matz: They could also end by virtue of divorce.
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Kevin Matz: And what happens if you created such a trust, and it ends by virtue of divorce? And there were some very sobering figures that were stated by Bruce Stone in his presentation.
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Kevin Matz: 42% of first marriages end in divorce.
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Kevin Matz: 66% of second marriages end a divorce. Nearly 3 quarters of third marriages end in divorce. So…
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Kevin Matz: Therefore, isn't it reasonable to think that there could be a conflict at some time during the course of a representation of both spouses?
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Kevin Matz: And therefore, isn't it reasonable to think that, as estate planners, if we're representing both spouses, maybe one spouse is a little bit more dominant.
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Kevin Matz: We have to make very, very clear that both spouses understand what's being communicated to them, maybe have sessions, just go over it by Zoom or in person. Make sure they understand
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Kevin Matz: And make sure we document it in writing.
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Kevin Matz: And, you know, that raises a whole bunch of questions, including under the ethical rules, what if, and at Bruce Stone, positive situations, what if one spouse says, don't tell my spouse, but I'm a secret non-marital child?
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Kevin Matz: Or There's someone else…
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Kevin Matz: Secret paramour. Want a benefit? Don't tell my spouse. What happens if you're representing both?
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Kevin Matz: And this is gonna come… this is a pickle to be in. The answer to it's going to depend upon state law, and also the terms of the engagement letter.
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Kevin Matz: But also, what happens in planning, even aside from that, Quite often for flexibility.
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Kevin Matz: It's desire to have a quote-unquote floating spouse concept. A floating spouse concept is the spouse of one happens to be married to, Grenner happens to be married to.
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Kevin Matz: From time to time. Which, if you're only representing, say, Grana or, say, a husband, let's say husband in this situation, maybe that's not a problem. But if you're representing both.
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Kevin Matz: You know, you have to be very clear that this means that if after, you know, if the wife were to die, and the husband were to remarry.
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Kevin Matz: then that second spouse, or third, or fourth spouse, whatever it may be, could also be a beneficiary of the trust… of the trust that's being set up. The spousal life and assets trust that's being set up.
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Kevin Matz: Also, it means that if there were to be a divorce.
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Kevin Matz: then a subsequent spouse would step into the shoes of the divorced ex-spouse as a beneficiary. And that's something that if you're representing both spouses in estate planning, the importance
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Kevin Matz: of what was shared at Heckerling, and I fully agree with, is that has to be communicated to both spouses so they understand exactly what this floating spouse concept means. Now, we had a recent case that brought it to its head.
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Kevin Matz: And that's a New York lower court case of C.S. versus RH, and this got a tremendous amount of discussion, throughout Heckerling and its implications. So here.
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Kevin Matz: We had a situation in which a husband created an irreparable grant of trust.
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Kevin Matz: For the benefit of his daughter, and also grandchildren. And marital property.
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Kevin Matz: as defined for New York law purposes, was used to fund those trusts.
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Kevin Matz: So you had the husband in 2001 create those trusts, for the benefit of the daughter and grandchildren, transfer marital assets to the trust. The husband, RH, had the ability to remove and replace the trustee. He could also swap assets via power substitution.
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Kevin Matz: Husband maintained the ability to manage the trust's assets for investment purposes via LLCs that were owned by the trust.
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Kevin Matz: After the wife brought a divorce action.
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Kevin Matz: The husband, who had various investment authorities, including the LLC, basically cut her off from the assets.
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Kevin Matz: Including, certain marital homes that were transferred to the Removal Trust, basically evicted.
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Kevin Matz: evicted her. And then mid-trial, he said, I want further protection, let's decant these trusts to Delaware, okay? And we'll get better, we'll get better, protection from the courts. I can tell you the New York court did not appreciate that.
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Kevin Matz: And there was testimony at trial, the wife testified at trial, that her husband assured her these trusts were set up as tax shelters. And she would forever have a role in these trusts, and their assets would
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Kevin Matz: would be enjoyed by her. Don't worry, honey, you're going to continue to enjoy it. Just sign here. Now, the wife did not have her own separate counsel.
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Kevin Matz: She testified that she was informed by her estate planning lawyer, who represented both her and her husband, that she was not informed what would happen to the assets in the event of divorce. So, the court looked at this. Again, we're not talking about a trust and estates matter in surrogates court or probate court.
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Kevin Matz: We're not talking about a tax matter, a tax, although this could potentially have tax implications, think in terms of Section 2036 or 2038. Extreme provisions to everybody code if the husband were to die. But the court said the value of these… of the trust assets, we're going to include in the marital estate.
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Kevin Matz: For purposes of the equitable distribution to the wife.
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Kevin Matz: Even though these trusts were valid trusts and were not a sham.
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Kevin Matz: And the court said, we're going to award the wife 50% of the value of
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Kevin Matz: the husband's holdings, including these trust assets, and we're going to establish a sequence. Sequence is the husband's non-trust assets are to satisfy the equitable distribution award first.
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Kevin Matz: And even though this will render the husband insolvent, we think that the husband will be sufficiently enterprising, and will be able to figure out a way to borrow from the trust, or otherwise receive distributions from those irrevo trusts, as to which he is not a beneficiary.
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Kevin Matz: not a beneficiary, to be able to satisfy the balance of the ward to their spouse. Again, there were not enough marital assets available to pay the wife, so essentially, this rendered the husband insolvent. Now, again, lots of discussion, heckling.
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Kevin Matz: This was not a tax case, but question, what if the IRS were to say, aha, if the husband were to die here?
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Kevin Matz: You thought you had a revable gift, but you were able to access these, enjoy these assets, including to provide, pursuant to the court order.
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Kevin Matz: To access these assets, to, to satisfy your legal obligation of equitable distribution.
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Kevin Matz: Husband were to die, is there inclusion under Section 2036, or probably more technically more correct, 2038, and then to Revenue Code?
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Kevin Matz: And then question, how do you avoid this? You know, do you maybe have separate counsel in the estate planning for husband and wife? Again, reverting to that issue I stated. Or maybe you have independent trustees and independent LLC managers. Again, you hear you add the husband as the investment manager.
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Kevin Matz: So, that permeated throughout all the discussions at Heckerling.
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Kevin Matz: And I see my time is up. I think I've covered everything, at least to a little extent, but those were the key issues that were presented at Heckerling this past year. Again, if you haven't attended the conference, strongly, strongly suggest that you consider it next January. It is the place to be, a place to come together as a profession.
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Kevin Matz: And as an industry, and I hope to see you there!
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Jonathan Shenkman: Great. Thank you so much, Kevin, and if anyone has any specific questions, new business opportunities, or any other issues they'd like to discuss, please feel free to reach out directly to Kevin or myself where appropriate, and I'll be sure to include his contact information in the follow-up email to the program, in addition to the slide deck, which I've already included in the reminder emails, but I'll send it out again tomorrow morning. Three more quick ideas before I let you go. First, my next webinar is
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Jonathan Shenkman: on Tuesday, March 24th, on Retirement 2.0, Modern Retirement Planning Strategies for 2026, featuring yours truly, Jonathan I. Shankman, President and CIO of Park Bridge Wealth Management, and I'll be sure to send out the invitation to this program in the coming days. In the meantime, if you have a friend or colleague
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Jonathan Shenkman: who would find these webinars of interest, they can subscribe to my webinar distribution list by going to parkbridgewealth.com forward slash webinars. Second, you can follow all my work on X and Instagram at Jonathan on Money by connecting with me on LinkedIn. You could also listen to my weekly podcast called Jonathan on Money, which is available on Apple, Spotify, or wherever you get your podcasts. And you can watch my practical planning videos, which I post several times a week.
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Jonathan Shenkman: by following me on YouTube at Jonathan on Money as well. And third, please take 30 seconds to fill out my survey at the end of this program. It helps me improve my webinars and provide timely and interesting content to attendees, and I thank you in advance for that. And with that, this concludes today's session. Please stay safe and healthy, and have a wonderful day, everybody.