Webinar: Fixing the Missed Portability Election: §9100 Relief, Rev. Proc. 2022-32 & the DSUE Amount by ALFi

Missing a portability election doesn't have to mean losing millions in future estate tax savings for your clients.

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Presenters

Jake Polivka

Estate Director

Jake Polivka is the Estate Director at Frost Law and is equipped with a strong foundation in Estate & Trust Planning and Administration. A graduate of the University of Maryland Carey School of Law and University of Maryland, College Park, Jake is well-versed in navigating the complexities of estate planning. He is licensed to practice in Maryland and the District of Columbia. His commitment to the community is evident through his involvement with the Maryland Pro Bono Resource Center's Estate Planning clinic and membership in the Baltimore Estate Planning Council.

Peter Haukebo

Peter Haukebo is a tax controversy attorney and Partner at Frost Law, where he represents clients in complex federal and state tax disputes. His practice includes handling IRS audits, appeals, and litigation with a particular focus on employment tax controversies and the Employee Retention Credit. Peter frequently presents to national audiences on tax procedure and controversy topics, blending technical insights with practical strategies. He is admitted to practice in Arizona and Maryland and before the United States Tax Court, Court of Federal Claims, Court of International Trade, and several District Courts. Peter previously taught in the Low Income Taxpayer Clinic at the University of Maryland School of Law and chaired the Taxation Section of the Maryland State Bar Association.

About

Program Field of Study: Taxes / Federal Tax Related Matters
Program Level: Basic
Credits: 1 CE | 1 CPE
Advanced Preparation: None
Prerequisite: None

Frost Law attorneys Peter Haukebo, Esq., and Jake Polivka, Esq., join the Accounting, Legal, & Finance Institute (ALFi) for a session that explains both correction paths using IRS rulings as a guide. The discussion covers what works, what fails, and why a fixed federal return can still leave state issues exposed.

Agenda

Identify which of the two relief paths applies to a given estate based on its size and time elapsed since death
Analyze recent Private Letter Ruling grants and denials to recognize fact patterns the IRS favors and the recurring pitfalls that lead to denial
Evaluate the strategic value of retaining counsel to pursue a PLR, weighing user fees and processing timelines against the certainty gained versus litigating the issue later
Discuss the limits on relying on published PLRs under §6110(k)(3)