Education

The Four Paths to Portability
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Jonathan G. Blattmachr, Esq., and Robert S. Keebler, CPA
November 11, 2026
Description:

Since portability became law, no single best structure or best practice has emerged. Estate planners must carefully consider each client’s unique situation. And while portability was a simplification and an improvement, the need to fix mistakes remains.

The best structure for a particular client varies. Should you still use the traditional bypass trust? A QTIP trust? Or is the marital deduction plus portability simply good enough? And for clients who don’t appear to have an estate tax liability, should you file for portability anyway?

Many families will also need to overcome mistakes or recalibrate their plans. Late elections can be difficult, but they can have tremendous value.

In this program you’ll learn:

  • The planning opportunity confirmed by Rev. Proc. 2016-49
  • The simplified procedure for late elections under Rev. Proc. 2022-32 (which superseded Rev. Proc. 2017-34)
  • Making the election on a timely filed return
  • How to file a portability-only return
  • How to receive late election relief under the streamlined procedure
  • The basics of 9100 relief
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Continuing Education Credits
InterActive Legal is not an approved Continuing Education (CE) Sponsor. However, several states and regulatory agencies for a variety of professionals that participate on our teleconferences may still receive continuing education credit for their participation. If a participant wishes to receive CE credit for their participation in these teleconferences, they must apply to receive credit on their own and through their individual states and regulatory authorities. It is the responsibility of the participant to file for CE credit and is not guaranteed by the webinar sponsors.
Jonathan G. Blattmachr, Esq.
Jonathan G. Blattmachr, Esq. thumbnail

Mr. Blattmachr is a Principal in ILS Management, LLC and a retired member of Milbank Tweed Hadley & McCloy LLP in New York, NY and of the Alaska, California and New York Bars. He is recognized as one of the most creative trusts and estates lawyers in the country and is listed in The Best Lawyers in America. He has written and lectured extensively on estate and trust taxation and charitable giving.

Mr. Blattmachr graduated from Columbia University School of Law cum laude, where he was recognized as a Harlan Fiske Stone Scholar, and received his A.B. degree from Bucknell University, majoring in mathematics. He has served as a lecturer-in-law of the Columbia University School of Law and is an Adjunct Professor of Law at New York University Law School in its Masters in Tax Program (LLM). He is a former chairperson of the Trusts & Estates Law Section of the New York State Bar Association and of several committees of the American Bar Association. Mr. Blattmachr is a Fellow and a former Regent of the American College of Trust and Estate Counsel and past chair of its Estate and Gift Tax Committee. He is author or co-author of eight books and more than 500 articles on estate planning and tax topics.

Among professional activities, which are too numerous to list, Mr. Blattmachr has served as an Advisor on The American Law Institute, Restatement of the Law, Trusts 3rd; and as a Fellow of The New York Bar Foundation and a member of the American Bar Foundation.

Robert S. Keebler, CPA
Robert S. Keebler, CPA thumbnail

Robert S. Keebler, CPA/PFS, MST, AEP (Distinguished) is a partner with Keebler & Associates, LLP and is a 2007 recipient of the prestigious Accredited Estate Planners (Distinguished) award from the National Association of Estate Planners & Councils.  

He has been named by CPA Magazine as one of the Top 100 Most Influential Practitioners in the United States and one of the Top 40 Tax Advisors to Know During a Recession. His practice includes family wealth transfer and preservation planning, charitable giving, retirement distribution planning, and estate administration.  

Mr. Keebler frequently represents clients before the National Office of the Internal Revenue Service (IRS) in the private letter ruling process and in estate, gift and income tax examinations and appeals, and he has received more than 250 favorable private letter rulings including several key rulings of “first impression.”  He is the author of over 100 articles and columns and is the editor, author or co-author of many books and treatises on wealth transfer and taxation. Mr. Keebler has been a speaker at national estate planning and tax seminars for over 25 years including the AICPA’s: Estate Planning, High Income, Advanced Financial Planning Conferences, ABA Conferences, NAPEC Conferences, The Notre Dame Estate Planning Conference and the Heckerling Estate Planning Institute and is the immediate past chair of the AICPA’s Advanced Estate Planning Conference.

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