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The Dow rocketed to a fresh record Friday, extending a post-election US equity rally while the euro retreated against the dollar following weak eurozone data. The blue-chip index piled on one percent to end the day at 44,296.51, narrowly overtaking a record set earlier this month. Major American indices have been at or near record territory since the US election, with investors betting that President-elect Donald Trump's program of tax cuts and regulatory scale-back would more than offset the drag from expected tariff increases. "The trading most of this week has been influenced by the growth agenda," said Jack Ablin, chief investment officer at Cresset Capital Management. Market watchers have been cheered this week by a broadening of the rally beyond the tech names that dominated earlier in the year. The dollar also continued to strengthen, reflecting less certainty about additional Federal Reserve interest rate cuts and the US currency's status as a haven asset amid escalating tensions in the Russia-Ukraine war. The euro was also battered by a closely watched survey showing contractions in November business activity in the eurozone. The HCOB Flash Eurozone purchasing managers' index (PMI) published by S&P Global dropped to 48.1 compared to 50.0 in October, the most marked rate of contraction in 10 months. Any reading above 50 indicates growth, while a figure below 50 shows contraction. "Things could hardly have turned out much worse," said Cyrus de la Rubia, chief economist at Hamburg Commercial Bank. "The eurozone's manufacturing sector is sinking deeper into recession, and now the services sector is starting to struggle after two months of marginal growth." But as the euro fell both Paris and Frankfurt stocks managed to recover their losses and advance. "The eurozone data has increased the chance of more rate cuts from the ECB next year," said Kathleen Brooks, research director at XTB, as well a cut of 50 basis points next month. "Investors have been jolted into recalibrating interest rate expectations on the back of this bleak economic news," she added. London managed to gain 1.4 percent despite data showing that retail sales figures for October undershot forecasts, as the pound fell against the dollar. In Asia, Tokyo climbed as the government prepared to announce a $140 billion stimulus package to kickstart the country's stuttering economy. However, Hong Kong and Shanghai sank on a sell-off in tech firms caused by weak earnings from firms including Temu-owner PDD Holdings and internet giant Baidu. Bitcoin set a new record high above $99,500 Friday, before easing back slightly. The leading digital currency is expected to soon burst through $100,000 as investors grow increasingly hopeful that Trump will pass measures to deregulate the crypto sector. Bitcoin has soared more than 40 percent since the Republican's election victory this month and has more than doubled since the turn of the year. The recent surge has also been "driven by news that Trump could set up an official crypto department that would sit in the heart of US government," said XTB's Brooks. New York - Dow: UP 1.0 percent at 44,296.51 (close) New York - S&P 500: UP 0.4 percent at 5,969.34 (close) New York - Nasdaq Composite: UP 0.2 percent at 19,003.65 (close) London - FTSE 100: UP 1.4 percent at 8,262.08 (close) Paris - CAC 40: UP 0.6 percent at 7,255.01 (close) Frankfurt - DAX: UP 0.9 percent at 19,322.59 (close) Tokyo - Nikkei 225: UP 0.7 percent at 38,283.85 (close) Hong Kong - Hang Seng Index: DOWN 1.9 percent at 19,229.97 (close) Shanghai - Composite: DOWN 3.1 percent at 3,267.19 (close) Euro/dollar: DOWN at $1.0418 from $1.0474 on Thursday Pound/dollar: DOWN at $1.2530 from $1.2589 Dollar/yen: UP at 154.83 yen from 154.54 yen Euro/pound: DOWN at 83.11 pence from 83.20 pence West Texas Intermediate: UP 1.6 percent at $71.24 per barrel Brent North Sea Crude: UP 1.3 percent at $75.17 per barrel burs-jmb/mlmShort Interest in JE Cleantech Holdings Limited (NASDAQ:JCSE) Increases By 1,285.0%

In a post on X on Saturday, Araghchi highlighted the partnership's resilience and its foundation on shared values and interests. "The Iran-China strategic partnership is ironclad because it's underpinned by cultural and civilizational bonds and rooted in shared values and interests," he stated. The minister's comments come amid high-level talks in Beijing, where Iran and China reaffirmed their commitment to regional stability. “With expanding conflict & terrorism in our region - amid malign attempts at domineering on the global level - Iran and China are determined more than ever to uphold the rule of law and preserve stability.” Araghchi also pointed to shared efforts by Tehran and Beijing to combat regional instability and uphold the rule of law, asserting that the Middle East's future should be determined by its own people. During his visit to Beijing, the Iranian foreign minister met with his Chinese counterpart Wang Yi, where both sides emphasized the strategic importance of their bilateral cooperation. The Global Times reported that the two diplomats underscored the role of this partnership in promoting regional peace and stability, as well as its global implications. Wang Yi reaffirmed China’s support for political dialogue to resolve the Iranian nuclear issue, stressing the need for all parties involved to contribute constructively to the restoration of the Joint Comprehensive Plan of Action (JCPOA). He added that all relevant parties should play a constructive role in reviving negotiations and refrain from repeated sanctions and pressure. Araghchi, for his part, expressed appreciation for China’s key role in preserving the Iran nuclear deal, further noting that Iran remains committed to deepening ties with China. He stressed that expanding strategic relations with Beijing is a priority for Iran's foreign policy. The two diplomats also urged the need for implementing the Iran-China Comprehensive Cooperation Deal, which aims to enhance political, economic, cultural, and technological exchanges between the two nations. 9341**2050

The Showdown: Jam-packed Nebraska week starts with in-state rivalry doubleheaderROCK HILL, S.C., Nov. 26, 2024 (GLOBE NEWSWIRE) -- 3D Systems Corporation DDD announced today its financial results for the third quarter ended September 30, 2024. Third Quarter Highlights (All numbers are unaudited and are presented in millions, except per share amounts or as otherwise noted) Revenue of $112.9 million decreased 9% year-over-year primarily driven by macro weakness in printer sales, partially offset by approximately 10% growth in consumables sales Healthcare Solutions revenue of $55.1 million grew 5% year-over-year, led by strong growth in Dental and Personalized Healthcare solutions Customer interest in 3D printing applications continued to gain momentum, with revenues in the Application Innovation Group (AIG) growing over 26% year-to-date versus prior year across industrial markets Q3'24 gross profit margin of 36.9% and Non-GAAP gross profit margin (1) of 37.6% included a $3 million headwind related to an increase in inventory reserves - if excluded, Non-GAAP gross profit margin was 40.2% Q3'24 net loss of $178.6 million, diluted loss per share of $1.35, which includes $143.7 million associated with the impairment of goodwill and other long-lived assets. Non-GAAP diluted loss per share (1) of $0.12 Q3'24 negative Adjusted EBITDA (1) of $14.3 million Updating guidance for remainder of FY'2024 to now include expected full-year revenues within the range of $440 million - $450 million Unaudited Three Months Ended September 30, Three Months Ended September 30, (in millions, except per share data) 2024 2023 Revenue $ 112.9 $ 123.8 Gross profit 41.7 55.4 Gross profit margin 36.9 % 44.7 % Operating expense 222.5 68.9 Loss from operations (180.8 ) (13.6 ) Net loss attributable to 3D Systems Corporation (178.6 ) (11.7 ) Diluted loss per share (1.35 ) (0.09 ) Non-GAAP measures for year-over-year comparisons: (1) Non-GAAP gross profit margin 37.6 % 44.8 % Non-GAAP operating expense 61.4 55.8 Adjusted EBITDA (14.3 ) 4.7 Non-GAAP diluted (loss) income per share $ (0.12 ) $ 0.01 (1) See "Presentation of Information in this Press Release" below for a description, and the Appendix for reconciliations of non-GAAP measurements to the most closely comparable GAAP measures. Summary Comments on Results Commenting on third quarter results, Dr. Jeffrey Graves, president and CEO of 3D Systems said, "As recently shared, our third quarter revenues continued to be impacted by sluggish capital investments by our customers for new production capacity, particularly in the Industrial markets, impacting the sale of new printing systems. On a positive note however, capacity utilization for our installed printer fleet broadly increased, translating into an increase in consumable revenues, which grew nearly 10% on both prior year and sequential comparisons. While 2024 has been a challenging year for new printer system sales, we are increasingly encouraged about the future, driven in large part by customer demand for our Application Innovation Group, a group of highly skilled process specialists who assist customers in developing new applications for 3D printing. Year-to-date this group, which spans both polymer and metal solutions, has experienced a rise of over 26% in revenues derived from new application development, particularly in highly regulated markets such a semiconductor equipment manufacturing, oil & gas, aerospace & defense markets, and our medical markets. Much of this performance, and the future growth potential it implies, has been fueled by an aggressive cycle of innovation at our company, enabled by our sustained focus on new product innovation across all of our major polymer and metal printing solutions. As a result of this sustained focus, which we believe differentiates us from many others in our industry, we are on pace to deliver nearly 40 new products to market since the third quarter of last year, and 25 in calendar 2024 alone. We believe no other company in our industry has matched this output that we expect will pay dividends in growth and profitability improvements as the economy rebounds in the future." Dr. Graves continued, "Given our strong focus on new product innovation, over the last two years we've also completely altered our manufacturing model from nearly 100% outsourced, to taking full responsibility for our integrated supply chain by in-sourcing procurement, assembly operations and logistics. This transition is now virtually complete, and, while it required short-term increases in expenses and working capital, we believe it is absolutely essential in driving smooth new product introductions, high quality product and delivery performance and, importantly, long-term customer satisfaction and gross margin improvements as factory efficiencies increase. While weakness in our end-markets over the last several quarters has muted these benefits, as volumes recover we expect to realize them increasingly over time. With our in-sourcing efforts now close to completion, our near term focus has shifted to managing working capital and capex spend to improve cash performance. This has been increasingly effective as we entered the second half of the year, as demonstrated by the stabilization of our cash reserves in the third quarter. We were also pleased to deliver a sequential reduction in operating expenses, in line with our previous expectations, and expect the benefits of restructuring actions previously taken to positively impact our cost structure in the quarters ahead." Dr. Graves concluded, "As we look to the end of the year, the consistent fueling of our R&D engines as we moved through a tougher macro environment period is now driving an acceleration of exciting new customer applications, supported by outstanding new products spanning from new printer hardware to advanced engineering materials, to enhancement of our software capabilities. We believe this positions us well as the geopolitical and economic headwinds of the last 18 months ultimately begin to recede. Given timing uncertainties and normal quarter-to-quarter inventory management at year-end, we believe it is prudent to be conservative in our outlook for the full year. As such, we are updating our revenue expectations for the full year 2024 to be between $440 million and $450 million. From an OPEX perspective, we expect to see continued improvement consistent with our prior comments, namely that OPEX will decrease again in Q4, to below $60 million. These combined factors should yield a sequential improvement in Adjusted EBITDA and will place us on a trajectory towards profitability in the quarters ahead. We will continue our balanced view of short-term focus on cash performance and improving profitability, while meeting the longer-term needs of our customers from a technology and service perspective. In keeping our customers' production goals clearly in our sites each day, we believe that substantial long-term value will be created for all of our stakeholders in the years ahead." Summary of Third Quarter Results Revenue for the third quarter of 2024 decreased approximately 9% to $112.9 million compared to the same period last year, primarily driven by lower printer sales, partially offset by approximately 10% growth in materials. Gross profit margin for the third quarter of 2024 was 36.9% compared to 44.7% for the same period last year. Non-GAAP gross profit margin was 37.6% compared to 44.8% for the same period last year. Gross profit margin decreased primarily due to unfavorable absorption associated with lower volumes and approximately $3 million associated with an increase in inventory reserves, partially offset by favorable mix. In addition, gross profit margin from the prior year period includes approximately $4.5 million of incremental revenue recognized by our Regenerative Medicine business at 100% margin related to incremental milestone recognition which did not repeat in the third quarter of 2024. Operating expense for the third quarter of 2024 was $222.5 million compared to $68.9 million for the same period last year and includes $143.7 million associated with the impairment of goodwill and other long-lived assets taken during the third quarter of 2024. Non-GAAP operating expense of $61.4 million increased $5.6 million compared to the same period last year, while improving $2.7 million on a sequential basis. The sequential improvement was primarily driven by benefits associated with prior restructuring actions. Net loss attributable to 3D Systems Corporation for the third quarter of 2024 was $178.6 million compared to a net loss of $11.7 million for the same period last year. The decline from prior year was primarily impacted by the previously referenced $143.7 million associated with the impairment of goodwill and other long-lived assets taken during the third quarter of 2024. Adjusted EBITDA decreased by $19.1 million to a loss of $14.3 million in the third quarter of 2024 compared to the same period last year. The decrease in Adjusted EBITDA primarily reflects lower revenue, lower gross margin and higher operating expense. As previously noted, the third quarter of 2023 also included the benefit of approximately $4.5 million of incremental milestone recognition by our Regenerative Medicine business at 100% margin that did not repeat in the third quarter of 2024. Updating 2024 Outlook Based on current macroeconomic and geopolitical conditions, 3D Systems is updating its financial guidance for the remainder of 2024 as follows: Revenues for the full-year 2024 within the range of $440 million - $450 million Non-GAAP gross profit margin for the full-year 2024 within the range of 38% - 40% Maintain the expectation for Non-GAAP operating expense of less than $60 million for Q4'24 Adjusted EBITDA to improve sequentially Financial Liquidity At September 30, 2024, the company had cash and cash equivalents of $190.0 million, a decrease of $141.5 million since December 31, 2023. The decrease resulted primarily due to cash used in operations of $37.1 million, capital expenditures of $10.8 million, and repayment on borrowings of $87.2 million. At September 30, 2024, the company had total debt, net of deferred financing costs of $211.7 million. Q3 2024 Conference Call and Webcast The company will host a conference call and simultaneous webcast to discuss these results on November 27, 2024, which may be accessed as follows: Date: Wednesday, November 27, 2024 Time: 8:30 a.m. Eastern Time Listen via webcast: www.3dsystems.com/investor Participate via telephone: 201-689-8345 A replay of the webcast will be available approximately two hours after the live presentation at www.3dsystems.com/investor . Forward-Looking Statements Certain statements made in this release that are not statements of historical or current facts are forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. Forward-looking statements involve known and unknown risks, uncertainties and other factors that may cause the actual results, performance or achievements of the company to be materially different from historical results or from any future results or projections expressed or implied by such forward-looking statements. In many cases, forward looking statements can be identified by terms such as "believes," "belief," "expects," "may," "will," "estimates," "intends," "anticipates" or "plans" or the negative of these terms or other comparable terminology. Forward-looking statements are based upon management's beliefs, assumptions and current expectations and may include comments as to the company's beliefs and expectations as to future events and trends affecting its business and are necessarily subject to uncertainties, many of which are outside the control of the company. The factors described under the headings "Forward-Looking Statements" and "Risk Factors" in the company's periodic filings with the Securities and Exchange Commission, as well as other factors, could cause actual results to differ materially from those reflected or predicted in forward-looking statements. Although management believes that the expectations reflected in the forward-looking statements are reasonable, forward-looking statements are not, and should not be relied upon as a guarantee of future performance or results, nor will they necessarily prove to be accurate indications of the times at which such performance or results will be achieved. The forward-looking statements included are made only as the date of the statement. 3D Systems undertakes no obligation to update or revise any forward-looking statements made by management or on its behalf, whether as a result of future developments, subsequent events or circumstances or otherwise, except as required by law. Presentation of Information in this Press Release 3D Systems reports its financial results in accordance with GAAP. Management also reviews and reports certain non-GAAP measures, including: non-GAAP gross profit, non-GAAP gross profit margin, non-GAAP operating expense, non-GAAP diluted income (loss) per share, and Adjusted EBITDA. These non-GAAP measures exclude certain items that management does not view as part of 3D Systems' core results as they may be highly variable, may be unusual or infrequent, are difficult to predict and can distort underlying business trends and results. Management believes that the non-GAAP measures provide useful additional insight into underlying business trends and results and provide meaningful information regarding the comparison of period-over-period results. Additionally, management uses the non-GAAP measures for planning, forecasting and evaluating business and financial performance, including allocating resources and evaluating results relative to employee compensation targets. 3D Systems' non-GAAP measures are not calculated in accordance with or as required by GAAP and may not be calculated in the same manner as similarly titled measures used by other companies. These non-GAAP measures should thus be considered as supplemental in nature and not considered in isolation or as a substitute for the related financial information prepared in accordance with GAAP. To calculate the non-GAAP measures, 3D Systems excludes the impact of the following items: amortization of intangible assets, a non-cash expense, as 3D Systems' intangible assets were primarily acquired in connection with business combinations; costs incurred in connection with acquisitions and divestitures, such as legal, consulting and advisory fees; stock-based compensation expenses, a non-cash expense; charges related to restructuring and cost optimization plans, impairment charges, including goodwill, and divestiture gains or losses; impact of equity method investments; certain compensation expense related to the 2021 Volumetric acquisition; and costs, including legal fees, related to significant or unusual litigation matters. Amortization of intangibles and acquisition and divestiture-related costs are excluded from non-GAAP measures as the timing and magnitude of business combination transactions are not predictable, can vary significantly from period to period and the purchase price allocated to amortizable intangible assets and the related amortization period are unique to each acquisition. Amortization of intangible assets will recur in future periods until such intangible assets have been fully amortized. While intangible assets contribute to the company's revenue generation, the amortization of intangible assets does not directly relate to the sale of the company's products or services. Additionally, intangible assets amortization expense typically fluctuates based on the size and timing of the company's acquisition activity. Accordingly, the company believes excluding the amortization of intangible assets enhances the company's and investors' ability to compare the company's past financial performance with its current performance and to analyze underlying business performance and trends. Although stock-based compensation is a key incentive offered to certain of our employees, the expense is non-cash in nature, and we continue to evaluate our business performance excluding stock-based compensation; therefore, it is excluded from non-GAAP measures. Stock-based compensation expenses will recur in future periods. Charges related to restructuring and cost optimization plans, impairment charges, including goodwill, divestiture gains or losses, and the costs, including legal fees, related to significant or unusual litigation matters are excluded from non-GAAP measures as the frequency and magnitude of these activities may vary widely from period to period. Additionally, impairment charges, including goodwill, are non-cash. Furthermore, the company believes the costs, including legal fees, related to significant or unusual litigation matters are not indicative of our core business' operations. Finally, 3D Systems excludes contingent consideration recorded as compensation expense related to the 2021 Volumetric acquisition from non-GAAP measures as management evaluates financial performance excluding this expense, which is viewed by management as similar to acquisition consideration. The matters discussed above are tax effected, as applicable, in calculating non-GAAP diluted income (loss) per share. Adjusted EBITDA, defined as net income, plus income tax (provision) benefit, interest and other income (expense), net, stock-based compensation expense, amortization of intangible assets, depreciation expense, and other non-GAAP adjustments, all as described above, is used by management to evaluate performance and helps measure financial performance period-over-period. A reconciliation of GAAP to non-GAAP measures is provided in the accompanying schedules. 3D Systems does not provide forward-looking guidance for certain measures on a GAAP basis. The company is unable to provide a quantitative reconciliation of forward-looking non-GAAP gross profit margin, Adjusted EBITDA, and non-GAAP operating expense to the most directly comparable forward-looking GAAP measures without unreasonable effort because certain items, including litigation costs, acquisition expenses, stock-based compensation expense, intangible assets amortization expense, restructuring expenses, and goodwill impairment charges are difficult to predict and estimate. These items are inherently uncertain and depend on various factors, many of which are beyond the company's control, and as such, any associated estimate and its impact on GAAP performance could vary materially. About 3D Systems More than 35 years ago, 3D Systems brought the innovation of 3D printing to the manufacturing industry. Today, as the leading additive manufacturing solutions partner, we bring innovation, performance, and reliability to every interaction - empowering our customers to create products and business models never before possible. Thanks to our unique offering of hardware, software, materials and services, each application-specific solution is powered by the expertise of our application engineers who collaborate with customers to transform how they deliver their products and services. 3D Systems' solutions address a variety of advanced applications in Healthcare and Industrial Solutions markets such as medical and dental, aerospace & defense, automotive and durable goods. More information on the company is available at www.3dsystems.com . Tables Follow 3D Systems Corporation Unaudited Condensed Consolidated Balance Sheets September 30, 2024 and December 31, 2023 (in thousands, except par value) September 30, 2024 December 31, 2023 ASSETS Current assets: Cash and cash equivalents $ 190,005 $ 331,525 Accounts receivable, net of reserves — $2,137 and $3,389 99,224 101,497 Inventories 134,926 152,188 Prepaid expenses and other current assets 35,858 42,612 Total current assets 460,013 627,822 Property and equipment, net 53,907 64,461 Intangible assets, net 20,961 62,724 Goodwill 14,967 116,082 Operating lease right-of-use assets 49,384 58,406 Finance lease right-of-use assets 9,185 12,174 Long-term deferred income tax assets 4,041 4,230 Other assets 45,818 44,761 Total assets $ 658,276 $ 990,660 LIABILITIES, REDEEMABLE NON-CONTROLLING INTEREST AND EQUITY Current liabilities: Current operating lease liabilities $ 9,628 $ 9,924 Accounts payable 42,414 49,757 Accrued and other liabilities 44,882 49,460 Customer deposits 8,655 7,599 Deferred revenue 33,336 30,448 Total current liabilities 138,915 147,188 Long-term debt, net of deferred financing costs 211,682 319,356 Long-term operating lease liabilities 51,000 56,795 Long-term deferred income tax liabilities 5,214 5,162 Other liabilities 31,340 33,400 Total liabilities 438,151 561,901 Commitments and contingencies Redeemable non-controlling interest 2,093 2,006 Stockholders' equity: Common stock, $0.001 par value, authorized 220,000 shares; shares issued 134,826 and 133,619 as of September 30, 2024 and December 31, 2023, respectively 135 134 Additional paid-in capital 1,588,911 1,577,519 Accumulated deficit (1,328,536 ) (1,106,650 ) Accumulated other comprehensive loss (42,478 ) (44,250 ) Total stockholders' equity 218,032 426,753 Total liabilities, redeemable non-controlling interest and stockholders' equity $ 658,276 $ 990,660 3D Systems Corporation Unaudited Condensed Consolidated Statements of Operations Three and Nine Months Ended September 30, 2024 and 2023 Three Months Ended Nine Months Ended (in thousands, except per share amounts) September 30, 2024 September 30, 2023 September 30, 2024 September 30, 2023 Revenue: Products $ 72,968 $ 80,415 $ 208,752 $ 253,968 Services 39,972 43,376 120,345 119,253 Total revenue 112,940 123,791 329,097 373,221 Cost of sales: Products 47,533 47,427 129,571 153,442 Services 23,694 21,014 69,793 67,315 Total cost of sales 71,227 68,441 199,364 220,757 Gross profit 41,713 55,350 129,733 152,464 Operating expenses: Selling, general and administrative 57,974 33,355 166,772 150,623 Research and development 20,764 21,982 66,260 66,953 Asset impairment charges 143,733 13,597 143,733 13,597 Total operating expenses 222,471 68,934 376,765 231,173 Loss from operations (180,758 ) (13,584 ) (247,032 ) (78,709 ) Non-operating income (expense): Foreign exchange loss, net (1,960 ) (2,202 ) (774 ) (3,847 ) Interest income 1,550 5,841 5,800 15,730 Interest expense (606 ) (932 ) (1,944 ) (2,612 ) Other (loss) income, net (51 ) (105 ) 21,719 420 Total non-operating (loss) income (1,067 ) 2,602 24,801 9,691 Loss before income taxes (181,825 ) (10,982 ) (222,231 ) (69,018 ) Benefit (provision) for income taxes 4,343 (174 ) 2,496 (404 ) Loss on equity method investment, net of income taxes (1,254 ) (605 ) (2,403 ) (747 ) Net loss before redeemable non-controlling interest (178,736 ) (11,761 ) (222,138 ) (70,169 ) Less: net loss attributable to redeemable non-controlling interest (109 ) (57 ) (252 ) (149 ) Net loss attributable to 3D Systems Corporation $ (178,627 ) $ (11,704 ) $ (221,886 ) $ (70,020 ) Net loss per common share: Basic $ (1.35 ) $ (0.09 ) $ (1.69 ) $ (0.54 ) Diluted $ (1.35 ) $ (0.09 ) $ (1.69 ) $ (0.54 ) Weighted average shares outstanding: Basic 132,235 130,263 131,621 129,780 Diluted 132,235 130,263 131,621 129,780 3D Systems Corporation Unaudited Condensed Consolidated Statements of Cash Flows Nine Months Ended September 30, 2024 and 2023 Nine Months Ended (in thousands) September 30, 2024 September 30, 2023 Cash flows from operating activities: Net loss before redeemable non-controlling interest $ (222,138 ) $ (70,169 ) Adjustments to reconcile net loss to net cash used in operating activities: Depreciation, amortization and accretion of debt discount 28,837 27,054 Stock-based compensation 17,339 15,140 Loss on short-term investments — 6 Non-cash operating lease expense 7,370 6,552 Provision for inventory obsolescence 10,332 6,061 Provision for bad debts 148 197 Loss on the disposition of businesses, property, equipment and other assets 1,649 51 Gain on debt extinguishment (21,518 ) — Provision (benefit) for deferred income taxes and reserve adjustments 451 141 Loss on equity method investment, net of taxes 2,403 747 Asset impairment charges 143,733 14,856 Changes in operating accounts: Accounts receivable 2,594 (11,706 ) Inventories 5,972 (23,106 ) Prepaid expenses and other current assets 6,831 (2,790 ) Accounts payable (7,201 ) (7,717 ) Deferred revenue and customer deposits 4,533 1,351 Accrued and other liabilities (9,843 ) (16,066 ) All other operating activities (8,601 ) (12,495 ) Net cash used in operating activities (37,109 ) (71,893 ) Cash flows from investing activities: Purchases of property and equipment (10,798 ) (20,995 ) Sales and maturities of short-term investments — 180,925 Proceeds from sale of assets and businesses, net of cash sold 96 — Acquisitions and other investments, net of cash acquired (2,450 ) (29,241 ) Net cash (used in) provided by investing activities (13,152 ) 130,689 Cash flows from financing activities: Repayment of borrowings/long-term debt (87,218 ) — Taxes paid related to net-share settlement of equity awards (2,526 ) (4,752 ) Other financing activities (1,003 ) (463 ) Net cash used in financing activities (90,747 ) (5,215 ) Effect of exchange rate changes on cash, cash equivalents and restricted cash (530 ) 1,561 Net (decrease) increase in cash, cash equivalents and restricted cash (141,538 ) 55,142 Cash, cash equivalents and restricted cash at the beginning of the year (a) 333,111 391,975 Cash, cash equivalents and restricted cash at the end of the period (a) $ 191,573 $ 447,117 (a) The following table provides a reconciliation of cash, cash equivalents, and restricted cash reported within the condensed consolidated balance sheets to the total of such amounts reported in the condensed consolidated statements of cash flows. (in thousands) September 30, 2024 December 31, 2023 September 30, 2023 December 31, 2022 Cash and cash equivalents $ 190,005 $ 331,525 $ 445,554 $ 388,134 Restricted cash included in prepaid expenses and other current assets 122 119 118 114 Restricted cash included in other assets 1,446 1,467 1,445 3,727 Total cash, cash equivalents and restricted cash shown in the condensed consolidated statements of cash flows $ 191,573 $ 333,111 $ 447,117 $ 391,975 Amounts included in restricted cash as of September 30, 2024, December 31, 2023 and September 30, 2023 primarily relate to guarantees in the form of a standby letter of credit as security for a long-term real estate lease. Amounts included in restricted cash as of December 31, 2022 primarily relate to $3,435 deposited into an escrow account relating to the initial investment in the National Additive Manufacturing innovation ("NAMI") joint venture. The remaining amounts in restricted cash in all periods presented relate to collateral for letters of credit and bank guarantees. Appendix 3D Systems Corporation Unaudited Reconciliations of GAAP to Non-GAAP Measures Three and Nine Months Ended September 30, 2024 , 2023 Gross Profit and Gross Profit Margin (1) Three Months Ended September 30, (in millions) 2024 2023 Gross Profit Gross Profit Margin Gross Profit Gross Profit Margin GAAP $ 41.7 36.9 % $ 55.4 44.7 % Amortization expense included in Cost of sales 0.3 0.1 Severance accrual adjustment 0.5 — Non-GAAP (2) $ 42.5 37.6 % $ 55.5 44.8 % (1) Amounts in table may not foot due to rounding (2) Calculated as non-GAAP gross profit as a percentage of total revenue Nine Months Ended September 30, (in millions) 2024 2023 Gross Profit Gross Profit Margin Gross Profit Gross Profit Margin GAAP $ 129.7 39.4 % $ 152.5 40.9 % Amortization expense included in Cost of sales 0.8 0.1 Severance accrual adjustment (0.5 ) — Non-GAAP (2) $ 130.0 39.5 % $ 152.6 40.9 % (1) Amounts in table may not foot due to rounding (2) Calculated as non-GAAP gross profit as a percentage of total revenue Non-GAAP Operating Expense (1) Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2024 2023 2024 2023 Operating expense $ 222.5 $ 68.9 $ 376.8 $ 231.2 Amortization expense (8.1 ) (3.1 ) (12.4 ) (9.6 ) Stock-based compensation expense (5.8 ) 3.1 (17.4 ) (15.1 ) Acquisition and divestiture-related expense (0.6 ) 4.1 (0.8 ) (0.1 ) Legal and other expense (2.6 ) (2.1 ) (9.2 ) (4.9 ) Restructuring expense (0.2 ) (1.5 ) (1.4 ) (6.7 ) Asset impairment charges (143.7 ) (13.6 ) (143.7 ) (14.2 ) Non-GAAP operating expense $ 61.4 $ 55.8 $ 191.9 $ 180.6 (1) Amounts in table may not foot due to rounding Appendix 3D Systems Corporation Unaudited Reconciliations of GAAP to Non-GAAP Measures Three and Nine Months Ended September 30, 2024 , 2023 Net Loss to Adjusted EBITDA (1) Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2024 2023 2024 2023 Net loss attributable to 3D Systems Corporation $ (178.6 ) $ (11.7 ) $ (221.9 ) $ (70.0 ) Interest (income) expense, net (0.9 ) (4.9 ) (3.9 ) (13.1 ) Provision for income taxes (4.3 ) 0.2 (2.5 ) 0.4 Depreciation expense 4.6 5.1 14.5 15.7 Amortization expense 8.4 3.2 13.3 9.7 EBITDA (170.9 ) (8.2 ) (200.5 ) (57.4 ) Stock-based compensation expense 5.8 (3.1 ) 17.4 15.1 Acquisition and divestiture-related expense 0.6 (4.1 ) 0.8 0.1 Legal and other related costs 2.6 2.1 9.2 4.9 Restructuring expense 0.7 1.5 0.8 6.7 Net loss attributable to redeemable non-controlling interest (0.1 ) (0.1 ) (0.3 ) (0.1 ) Loss on equity method investments, net of tax 1.3 0.6 2.4 0.7 Gain on repurchase of debt — — (21.5 ) — Asset impairment charges 143.7 13.6 143.7 14.2 Other non-operating expense (income) 2.0 2.3 0.6 3.4 Adjusted EBITDA $ (14.3 ) $ 4.7 $ (47.3 ) $ (12.3 ) (1) Amounts in table may not foot due to rounding Appendix 3D Systems Corporation Unaudited Reconciliations of GAAP to Non-GAAP Measures Three and Nine Months Ended September 30, 2024 , 2023 Diluted Loss per Share (1) Three Months Ended September 30, Nine Months Ended September 30, (in dollars) 2024 2023 2024 2023 Diluted loss per share $ (1.35 ) $ (0.09 ) $ (1.69 ) $ (0.54 ) Stock-based compensation expense 0.04 (0.02 ) 0.13 0.12 Amortization expense 0.06 0.02 0.10 0.07 Acquisition and divestiture-related expense — (0.03 ) 0.01 — Legal expense 0.02 0.02 0.07 0.04 Asset impairment charges 1.09 0.10 1.09 0.11 Restructuring expense 0.01 0.01 0.01 0.05 Gain on repurchase of debt — — (0.16 ) — Loss on equity method investment and other 0.01 — 0.02 0.01 Non-GAAP diluted loss per share $ (0.12 ) $ 0.01 $ (0.42 ) $ (0.15 ) (1) Amounts in table may not foot due to rounding © 2024 Benzinga.com. Benzinga does not provide investment advice. All rights reserved.

Registration open for Wildsight Winter Forest and Nature SchoolMikel Arteta hailed the best away European performance of his Arsenal reign after watching his side dismantle Sporting Lisbon 5-1. The Gunners delivered the statement Champions League victory their manager had demanded to bounce back from a narrow defeat at Inter Milan last time out. Goals from Gabriel Martinelli, Kai Havertz, Gabriel Magalhaes, Bukayo Saka and Leandro Trossard got their continental campaign back on track, lifting them to seventh place with 10 points in the new-look 36-team table. It was Arsenal’s biggest away win in the Champions League since beating Inter by the same scoreline in 2003. “For sure, especially against opposition we played at their home who have not lost a game in 18 months – they have been in top form here – so to play with the level, the determination, the purpose and the fluidity we showed today, I am very pleased,” said Arteta. “The team played with so much courage, because they are so good. When I’m watching them live they are so good! They were all exceptional today. It was a big performance, a big win and we are really happy. “The performance was there a few times when we have played big teams. That’s the level that we have to be able to cope and you have to make it happen, and that creates belief.” A memorable victory also ended Sporting’s unbeaten start to the season, a streak of 17 wins and one draw, the vast majority of which prompted Manchester United to prise away head coach Ruben Amorim. The Gunners took the lead after only seven minutes when Martinelli tucked in Jurrien Timber’s cross, and Saka teed up Havertz for a tap-in to double the advantage. Arsenal added a third on the stroke of half-time, Gabriel charging in to head Declan Rice’s corner into the back of the net. To rub salt in the wound, the Brazilian defender mimicked Viktor Gyokeres’ hands-over-his-face goal celebration. That may have wound Sporting up as they came out after the interval meaning business, and they pulled one back after David Raya tipped Hidemasa Morita’s shot behind, with Goncalo Inacio netting at the near post from the corner. But when Martin Odegaard’s darting run into the area was halted by Ousmane Diomande’s foul, Saka tucked away the penalty. Substitute Trossard added the fifth with eight minutes remaining, heading in the rebound after Mikel Merino’s shot was saved. A miserable night for prolific Sporting striker Gyokeres was summed up when his late shot crashed back off the post.The Dow rocketed to a fresh record Friday, extending a post-election US equity rally while the euro retreated against the dollar following weak eurozone data. The blue-chip index piled on one percent to end the day at 44,296.51, narrowly overtaking a record set earlier this month. Major American indices have been at or near record territory since the US election, with investors betting that President-elect Donald Trump's program of tax cuts and regulatory scale-back would more than offset the drag from expected tariff increases. "The trading most of this week has been influenced by the growth agenda," said Jack Ablin, chief investment officer at Cresset Capital Management. Market watchers have been cheered this week by a broadening of the rally beyond the tech names that dominated earlier in the year. The dollar also continued to strengthen, reflecting less certainty about additional Federal Reserve interest rate cuts and the US currency's status as a haven asset amid escalating tensions in the Russia-Ukraine war. The euro was also battered by a closely watched survey showing contractions in November business activity in the eurozone. The HCOB Flash Eurozone purchasing managers' index (PMI) published by S&P Global dropped to 48.1 compared to 50.0 in October, the most marked rate of contraction in 10 months. Any reading above 50 indicates growth, while a figure below 50 shows contraction. "Things could hardly have turned out much worse," said Cyrus de la Rubia, chief economist at Hamburg Commercial Bank. "The eurozone's manufacturing sector is sinking deeper into recession, and now the services sector is starting to struggle after two months of marginal growth." But as the euro fell both Paris and Frankfurt stocks managed to recover their losses and advance. "The eurozone data has increased the chance of more rate cuts from the ECB next year," said Kathleen Brooks, research director at XTB, as well a cut of 50 basis points next month. "Investors have been jolted into recalibrating interest rate expectations on the back of this bleak economic news," she added. London managed to gain 1.4 percent despite data showing that retail sales figures for October undershot forecasts, as the pound fell against the dollar. In Asia, Tokyo climbed as the government prepared to announce a $140 billion stimulus package to kickstart the country's stuttering economy. However, Hong Kong and Shanghai sank on a sell-off in tech firms caused by weak earnings from firms including Temu-owner PDD Holdings and internet giant Baidu. Bitcoin set a new record high above $99,500 Friday, before easing back slightly. The leading digital currency is expected to soon burst through $100,000 as investors grow increasingly hopeful that Trump will pass measures to deregulate the crypto sector. Bitcoin has soared more than 40 percent since the Republican's election victory this month and has more than doubled since the turn of the year. The recent surge has also been "driven by news that Trump could set up an official crypto department that would sit in the heart of US government," said XTB's Brooks. New York - Dow: UP 1.0 percent at 44,296.51 (close) New York - S&P 500: UP 0.4 percent at 5,969.34 (close) New York - Nasdaq Composite: UP 0.2 percent at 19,003.65 (close) London - FTSE 100: UP 1.4 percent at 8,262.08 (close) Paris - CAC 40: UP 0.6 percent at 7,255.01 (close) Frankfurt - DAX: UP 0.9 percent at 19,322.59 (close) Tokyo - Nikkei 225: UP 0.7 percent at 38,283.85 (close) Hong Kong - Hang Seng Index: DOWN 1.9 percent at 19,229.97 (close) Shanghai - Composite: DOWN 3.1 percent at 3,267.19 (close) Euro/dollar: DOWN at $1.0418 from $1.0474 on Thursday Pound/dollar: DOWN at $1.2530 from $1.2589 Dollar/yen: UP at 154.83 yen from 154.54 yen Euro/pound: DOWN at 83.11 pence from 83.20 pence West Texas Intermediate: UP 1.6 percent at $71.24 per barrel Brent North Sea Crude: UP 1.3 percent at $75.17 per barrel burs-jmb/mlmQuill & Tears: Women Writers Who Changed Japan

Canada stocks lower at close of trade; S&P/TSX Composite down 0.02%One day, when actor and comedian Rosie O'Donnell was in her 50s, her body ached and her arms felt sore, but she pushed through the pain, not realizing she was having a massive heart attack. She had surgery to put in a stent that saved her life. Shortly after her 2012 heart attack, O'Donnell shared her experience on her blog. During her 2015 television standup special, she spoke about how the experience changed her life. The segment included a heart attack acronym the comedian coined: HEPPP (hot, exhausted, pain, pale, puke). O'Donnell's candidness about her heart attack helped spread awareness about how it can present differently in women. She's one of countless celebrities over the years who have opened up about their health conditions, including breast cancer, HIV, depression, heart disease and stroke. When celebrities reveal and discuss their health issues, the impact can be far-reaching. It not only helps to educate the public, but it also can reduce stigma and inspire others. "Health disclosures by celebrities do matter, and we know this from decades of research across a lot of different health conditions and public figures," said Dr. Jessica Gall Myrick, a professor of health communication at Pennsylvania State University in University Park. "They absolutely do influence people." Some of the earliest celebrity health disclosures happened in the 1970s and 1980s with U.S. presidents and first ladies. When first lady Betty Ford was diagnosed with breast cancer just weeks after Gerald Ford became president in 1974, she spoke openly about her diagnosis, inviting photographers into the White House and helping make talk of cancer less taboo. In 1987, first lady Nancy Reagan used her breast cancer diagnosis as a chance to advocate for women to get mammograms. Her disclosure came two years after President Ronald Reagan's colon cancer diagnosis, about which the couple was equally as vocal. "Individuals throughout the country have been calling cancer physicians and information services in record numbers," the Los Angeles Times reported after Nancy Reagan's widely publicized surgery. The public showed a similar interest years earlier following Betty Ford's mastectomy. Another major milestone in celebrity health disclosures came in 1991, when 32-year-old NBA superstar Earvin "Magic" Johnson revealed he had tested positive for HIV, the virus that causes AIDS. "Life is going to go on for me, and I'm going to be a happy man," Johnson assured fans during a news conference. He immediately retired, only to return to the Los Angeles Lakers in 1996. His disclosure, along with his work as an advocate for safe sex, helped shatter stigmas around HIV and AIDS. Calls to testing centers increased significantly in the days and weeks after Johnson's announcement. "That celebrity disclosure really helped people see there was a wider susceptibly to HIV," Gall Myrick said. "People were more likely to say, 'I need to think about my own risks.' It was very powerful." When it comes to heart and stroke health, helped make heart attacks less frightening and mysterious. During a news conference in 1955, millions of Americans learned from the president's doctors about his heart condition, his treatment, and concrete steps they could take to reduce their own heart attack risk. Other notable figures have shared their health experiences over the years. Soap opera legend , who was diagnosed with heart disease in 2018, has advocated for women's heart health. Basketball great Kareem Abdul Jabbar talks about his irregular heartbeat, known as atrial fibrillation, and advocates for regular health screenings. Lawyer, author and television personality continues to speak about heart disease risk after having lifesaving heart surgery in 2010. Longtime TV and radio personality Dick Clark brought stroke and aphasia into the national spotlight when he returned to hosting "New Year's Rockin' Eve" in Times Square just a year after his 2004 stroke and continued until his death in 2012. And actor and comedian Jamie Foxx recently revealed he had a stroke last year. "Celebrity disclosures represent teachable moments," said Dr. Seth M. Noar, director of the Communicating for Health Impact Lab at the University of North Carolina in Chapel Hill. "Searches for different health conditions often spike in the wake of these types of announcements. They cause people to think about these health issues, learn more about them, and in some cases change their behaviors." Celebrities have also highlighted the importance of CPR and the use of an automated external defibrillator, or AED, to restore a person's heartbeat if they experience cardiac arrest. Interest in CPR and AEDs spiked in 2023 after Buffalo Bills safety Damar Hamlin went into cardiac arrest during an NFL game broadcast on national TV. Views of the American Heart Association's hands-only CPR pages jumped more than 600% in the days following Hamlin's cardiac arrest. Three months later, around 3 million people had watched the AHA's CPR video. Family members of celebrities who have died from a heart issue have also spread awareness. After actor John Ritter died of an undiagnosed aortic dissection in 2003, his wife, actor Amy Yasbeck, started the Ritter Foundation to raise awareness about the condition and help others avoid a misdiagnosis. A published in Systematic Reviews in 2017 found that people are conditioned to react positively to celebrity advice. Research also has found that people often follow advice from celebrities who match how they perceive – or how they want to perceive – themselves. The most effective celebrity disclosures are frequently the ones that tell a compelling story and include clear steps people can take to apply lessons the celebrity learned to their own health situation, Gall Myrick said. "People are more likely to take action when they feel confident and capable." Research has shown that celebrity disclosures often impact calls to hotlines and page views on health-related websites, and they can spark behavioral and even policy changes. Anecdotally, Gall Myrick said, people ask their doctor more questions about health conditions and request medical screenings. Celebrities can have a big impact because people tend to have parasocial relationships with them, Gall Myrick said. These are one-sided relationships in which a person feels an emotional connection with another person, often a celebrity. People may feel as if they know the basketball player they've watched on the court for years, or the Hollywood actor they've followed, she said. They want to comfort them after a health disclosure. Social media has only increased this feeling of familiarity, as celebrities regularly share mundane – but fascinating – details of their daily lives, like what they eat for breakfast, their favorite socks, or the meditation they do before bed. "We spend a lifetime being exposed to celebrities through the media, and over time, you get to know these public figures," Gall Myrick said. "Some feel like friendships." A published in the journal Science Communication in 2020 compared reactions to actor Tom Hanks, who had COVID-19 early in the pandemic, and an average person with COVID-19. Researchers found that participants identified more with Hanks when it came to estimating their own susceptibility to COVID-19. The participants also felt more emotional about the virus that causes COVID-19 when thinking about it in relation to Hanks versus an average person. When a celebrity reveals a health condition, it's a surprise that may feel personal, especially if they are well-liked and the health issue is dramatic and sudden. "We feel like we know them, and the emotional response is what can then push people out of their routine," Gall Myrick said. Noar said a celebrity health story is often a more interesting and powerful way to learn about a health condition than just the facts, which can feel overwhelming. People are drawn to the slew of media coverage that typically follows a celebrity disclosure, he said. "Some of these high-visibility public figures' stories are now woven into some of these illnesses," Noar said. For example, Angelina Jolie is often linked to the BRCA1 gene mutation after the actor shared she had a preventive double mastectomy because of her elevated breast cancer risk and had her ovaries and fallopian tubes removed because of her increased risk for ovarian cancer. "It's a narrative, a story that humanizes the condition in a way that very informational communication really doesn't," Noar said. "People remember it, and it can potentially be a touch point." After a disclosure, patients may bring up a celebrity's story during a doctor's appointment and connect it to their own care. Today's multiplatform digital culture only amplifies celebrity messages. "You're seeing everyday people react to these events, and that can have a ripple effect too," Gall Myrick said. "We know from research that seeing messages more than once can be impactful. Often it's not just one billboard or one commercial that impacts behavior; it's the drip drip drip over time." Still, there's a cautionary tale to be told around the impact of celebrity health news, especially if the celebrity has died. An unclear cause of death may lead to speculation. Gall Myrick said that guesswork could potentially end up hurting rather than helping if patients were to act on misinformation or a lack of information. "Maybe the death was atypical or it needs more context," she said. "That's where advocacy groups and public health organizations come in. They need to be prepared for announcements or disclosures about celebrity deaths, and to fill in some of those gaps." covers heart and brain health. Not all views expressed in this story reflect the official position of the American Heart Association. Copyright is owned or held by the American Heart Association, Inc., and all rights are reserved. Sign up here to get the latest health & fitness updates in your inbox every week!

Celebrities can spark change when they speak up about their health* TSX ends down 0.02% at 25,405.14 * Energy falls 2.3%; oil settles 0.2% lower * Bombardier shares lose 9.3% * Technology advances 1.1% By Nikhil Sharma and Fergal Smith Nov 26 - Canada's stock market inched lower on Tuesday, weighed by declines for energy, railroad and auto parts manufacturing shares, after U.S. President-elect Donald Trump vowed to impose big tariffs on top trading partners, including Canada. The S&P/TSX composite index ended down 5.21 points, or 0.02%, at 25,405.14, its second straight day of modest declines after posting a record closing high on Friday. Trump on Monday pledged big tariffs on the United States' three largest trading partners - Canada, Mexico and China - in a move that helped push the Canadian dollar to a 4-1/2-year low against its U.S. counterpart. "Tariffs dump sand in the gears of the global economy and markets hate them," Colin Cieszynski, chief market strategist at SIA Wealth Management, said in a note. Officials from Mexico, Canada and China warned that Trump's tariff threat would harm the economies of all involved. "These types of threats are mostly designed to extract concessions," said Angelo Kourkafas, investment strategist at Edward Jones Investments, adding they are, however, "impacting sentiment in the short term." Canada sends about 75% of its exports to the United States, including oil. Trump's plan does not exempt crude oil from trade penalties, two sources familiar with the plan told Reuters. U.S. crude futures settled 0.25% lower at $68.77 a barrel after Israel agreed to a ceasefire deal with Lebanon, while the Toronto market's energy sector was down 2.3%. Industrials fell 1%, weighed by declines for railroad shares. Automotive suppliers also lost ground, with Magna International Inc falling 4.7%. Business jet manufacturer Bombardier Inc lost 9.3%. The TSX is set to rise in 2025 but returns could slow after investors potentially front-loaded much of the positive news, a Reuters poll found. Helping to limit the decline on Tuesday, technology rose 1.1% and financials added 0.5%. This article was generated from an automated news agency feed without modifications to text.Tech Titans in 2024: The Year AI Took Center Stage In 2024, the technological landscape was transformed by breakthroughs in artificial intelligence, leading to both spectacular gains and unexpected setbacks for key players. MicroStrategy soared past rivals, driven largely by its substantial Bitcoin reserves. As Bitcoin climbed to a staggering $108,000, MicroStrategy’s stock skyrocketed by over 440%, outpacing the cryptocurrency’s own growth. MicroStrategy’s strategic pivot in 2020, transitioning from software to Bitcoin holdings, proved fruitful. The company now claims nearly 2.2% of the Bitcoin supply. Critics argue the stock is overvalued, yet its five-year growth story is impressive. Meanwhile, Nvidia solidified its dominance in AI chip technology, achieving a 183% stock rise and reaching a massive $3.6 trillion market cap by November. This tech giant continues to meet the increasing demand for AI technologies, with projections indicating a sustained upward trajectory in sales and influence. Palantir Technologies navigated 2024 successfully, joining the Nasdaq 100, propelled by impressive earnings and a 378% stock increase. Its growth was underpinned by robust business performance and lucrative government projects. Yet, not all tech companies thrived. Once celebrated for its AI advancements, Super Micro Computer now grapples with accounting scandals and market cooling, causing its share value to drop significantly and its future to look uncertain. As industry juggernauts like Apple, Microsoft, and Tesla set the pace, the emergence of AI continues to shape these companies’ paths and challenge market dynamics. The sector faces regulatory hurdles and varied demand, making the future ever more uncertain. The Hidden Truths Behind AI’s Dominance in 2024 Understanding MicroStrategy’s Bold Bitcoin Move In 2024, MicroStrategy’s decision to pivot from software to Bitcoin holdings shines as a strategic foresight that exceeded expectations. By amassing nearly 2.2% of the Bitcoin supply, the company not only fortified its market position but also presented a unique investment case blending traditional corporate strategy with cryptocurrency ventures. This move has stirred debates among financial analysts, with some expressing skepticism over its long-term viability amidst broad market volatility. Nvidia’s Unmatched Surge in AI Technology With Nvidia’s market cap reaching a jaw-dropping $3.6 trillion, the company has solidified its position as a leader in AI chip technology. This achievement underscores the soaring demand for AI-powered solutions across various sectors, from autonomous vehicles to advanced data analytics. As Nvidia continues to innovate, its influence is expected to persist, fueling technological advancements that redefine industry standards. Palantir Technologies’ Ascension and Challenges Palantir Technologies’ inclusion in the Nasdaq 100 is a testament to its substantial growth backed by government collaborations and a resilient earnings trajectory. The company’s stock surge of 378% in 2024 highlights its strategic expansion into lucrative markets. However, analysts caution that maintaining this momentum will require navigating increasing competition and enhancing its data integration capabilities to meet diverse client needs. Super Micro Computer: The Roadblock of Scandals Unlike its peers, Super Micro Computer wrestles with reputational damage stemming from accounting controversies that have roiled investor confidence. As the AI market faces regulatory scrutiny and cooling investor sentiment, the company must address internal governance issues to reclaim its standing in the tech sphere. AI Regulatory Landscapes and Future Predictions As AI technologies carve more significant roles in various sectors, regulatory frameworks are poised to become more stringent. Companies will need to align their practices with evolving compliance standards to mitigate risks and embrace AI’s potential responsibly. This landscape presents both challenges and opportunities, sparking dialogue on ethical AI implementation and innovation. Emerging Insights and Innovations in AI The transformative power of AI is illustrated through emerging trends such as explainable AI, quantum computing compatibility, and sustainable AI development. Innovations in these areas promise to enhance transparency, computational power, and environmental stewardship, ensuring AI’s role as a pivotal force in global technological evolution. For more insights into these technological developments, visit MicroStrategy , Nvidia , and Palantir Technologies .

Outlook Therapeutics (NASDAQ:OTLK) Issues Quarterly Earnings Results

SANTA CLARA, Calif. , Nov. 26, 2024 /PRNewswire/ -- Couchbase, Inc. (NASDAQ: BASE), the cloud database platform company, today announced it has granted equity awards under its 2023 Inducement Equity Incentive Plan to new employees who joined Couchbase. On November 21, 2024 , Couchbase granted 9 non-executive employees equity awards in the form of service-based restricted stock units ("RSU Awards"), representing the right to receive up to 19,905 shares of Couchbase, Inc. common stock in the aggregate, with fifty percent (50%) of the shares subject to such RSU Awards vesting on the first quarterly vesting date following the one (1) year anniversary of the vesting commencement date, and twelve and one-half percent (12.5%) of the shares subject to such RSU Awards vesting on each quarterly vesting date thereafter conditioned upon each employee's continued employment on the vesting date(s). The inducement grants were approved by Couchbase's Compensation Committee of the Board of Directors, as required by Nasdaq Rule 5635(c)(4), and were granted as a material inducement to employment in accordance with Nasdaq Rule 5635(c)(4). About Couchbase Modern customer experiences need a flexible database platform that can power applications spanning from cloud to edge and everything in between. Couchbase's mission is to simplify how developers and architects develop, deploy and run modern applications wherever they are. We have reimagined the database with our fast, flexible and affordable cloud database platform Capella, allowing organizations to quickly build applications that deliver premium experiences to their customers– all with best-in-class price performance. More than 30% of the Fortune 100 trust Couchbase to power their modern applications. For more information, visit www.couchbase.com and follow us on X (formerly Twitter) @couchbase . Couchbase ® , the Couchbase logo and the names and marks associated with Couchbase's products are trademarks of Couchbase, Inc. All other trademarks are the property of their respective owners. View original content to download multimedia: https://www.prnewswire.com/news-releases/couchbase-announces-new-employee-inducement-grants-302316431.html SOURCE Couchbase, Inc.A sailor from Queanbeyan who was killed in an attack by Japanese suicide bombers in the Pacific in 1943 is to be honoured at the Australian War Memorial. Subscribe now for unlimited access . Login or signup to continue reading All articles from our website & app The digital version of Today's Paper Breaking news alerts direct to your inbox Interactive Crosswords, Sudoku and Trivia All articles from the other regional websites in your area Continue Able Seaman Leslie Laurence Hart died on January 5, 1945. He was 20 years old. On January 5, 2025, he will be remembered at the Last Post ceremony at the Australian War Memorial. He will be cited as a hero. "Leslie Hart was born in Queanbeyan on November 1, 1925, and grew up with his parents and sister in the Canberra suburb of Ainslie," the director of the Memorial, Matt Anderson, said. "On July 1, 1943 he enlisted in the Royal Australian Navy and, after five months' training, he joined the crew of HMAS Australia in early December 1943." He was one of 25 crewmen killed in an explosion caused by a kamikaze attack on the ship. More were to die in attacks in the following days. The warship Australia had been attacked from the air before, in October 1944, and that attack led to a debate in military circles about whether the Japanese had a new tactic of using pilots to die by suicide by ramming ships with their fighters in what became known as kamikaze attacks. The earlier, October attacks on the vessel seemed to be by aircraft which were already damaged and destined to crash, so the original intention of the pilot to die by suicide in the attack was unclear. But the January 1945 attacks were clearly kamikaze operations. Able Seaman Leslie Laurence Hart. Picture supplied by the Australian War Memorial "By January 5, 1945, she was back in action in the Lingayen Gulf covering the allied invasion of Luzon Island," the Royal Australian Navy account states. "Here she was subjected to repeated suicide attacks, this time there was no doubt of the kamikaze nature of the Japanese planes. Australia was hit on 5, 6, 8 and 9 January, losing three officers and 41 ratings killed and one officer and 68 ratings wounded. This was the ship's last action in World War II." Able Seaman Hart from Queanbeyan was one of those victims. His story will be related at the daily Last Post ceremony at the war memorial at 4.30pm on the anniversary of his death. "The Last Post Ceremony is our commitment to remembering and honouring the legacy of Australian service," Mr Anderson said. "The Last Post is now associated with remembrance but originally it was a bugle call to sound the end of the day's activities in the military. It is a fitting way to end each day at the memorial." Share Facebook Twitter Whatsapp Email Copy Steve Evans Reporter Steve Evans is a reporter on The Canberra Times. He's been a BBC correspondent in New York, London, Berlin and Seoul and the sole reporter/photographer/paper deliverer on The Glen Innes Examiner in country New South Wales. "All the jobs have been fascinating - and so it continues." Steve Evans is a reporter on The Canberra Times. He's been a BBC correspondent in New York, London, Berlin and Seoul and the sole reporter/photographer/paper deliverer on The Glen Innes Examiner in country New South Wales. "All the jobs have been fascinating - and so it continues." 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LONDON — Olivia Hussey, the actor who starred as a teenage Juliet in the 1968 film "Romeo and Juliet," died, her family said on social media Saturday. She was 73. Hussey died Friday "peacefully at home surrounded by her loved ones," a statement posted to her Instagram account said. Hussey was 15 when director Franco Zeffirelli cast her in his adaptation of the William Shakespeare tragedy after spotting her onstage in the play "The Prime of Miss Jean Brodie," which also starred Vanessa Redgrave. "Romeo and Juliet" won two Oscars and Hussey won a Golden Globe for best new actress for her part as Juliet, opposite British actor Leonard Whiting, who was 16 at the time. "Romeo and Juliet" movie director Franco Zeffirelli, left, and actors Olivia Hussey, center, and Leonard Whiting are seen Sept. 25, 1968, in Paris after the Parisian premiere of the film. Decades later Hussey and Whiting brought a lawsuit against Paramount Pictures alleging sexual abuse, sexual harassment and fraud over nude scenes in the film. Listen now and subscribe: Apple Podcasts | Google Podcasts | Spotify | RSS Feed | SoundStack | All Of Our Podcasts They alleged they were initially told they would wear flesh-colored undergarments in a bedroom scene, but on the day of the shoot Zeffirelli told the pair they would wear only body makeup and the camera would be positioned in a way that would not show nudity. They alleged they were filmed in the nude without their knowledge. The case was dismissed by a Los Angeles County judge in 2023, who found their depiction could not be considered child pornography and the pair filed their claim too late. Leonard Whiting, left, and Olivia Hussey arrive April 26, 2018, at the screening of "The Producers" at the 2018 TCM Classic Film Festival Opening Night at the TCL Chinese Theatre in Los Angeles. Whiting was among those who paid tribute to Hussey on Saturday. "Rest now my beautiful Juliet no injustices can hurt you now," he wrote. "And the world will remember your beauty inside and out forever." Hussey was born April 17, 1951, in Bueno Aires, Argentina, and moved to London as a child. She studied at the Italia Conti Academy drama school. She also starred as Mary, the mother of Jesus, in the 1977 television series "Jesus of Nazareth," as well as the 1978 adaptation of Agatha Christie's "Death on the Nile" and horror movies "Black Christmas" and "Psycho IV: The Beginning." She is survived by her husband, David Glen Eisley, her three children and a grandson. Glynis Johns, a Tony Award-winning stage and screen star who played the mother opposite Julie Andrews in the classic movie “Mary Poppins” and introduced the world to the bittersweet standard-to-be “Send in the Clowns” by Stephen Sondheim, died, Thursday, Jan. 4, 2023. She was 100. AP Photo/Carlos Rene Perez Adan Canto, the Mexican singer and actor best known for his roles in “X-Men: Days of Future Past” and “Agent Game” as well as the TV series “The Cleaning Lady,” “Narcos,” and “Designated Survivor,” died Monday, Jan. 8, 2024, after a private battle with appendiceal cancer. He was 42. Paul A. Hebert/Invision/AP, File Bud Harrelson, the scrappy and sure-handed shortstop who fought Pete Rose on the field during a playoff game and helped the New York Mets win an astonishing championship, died Thursday, Jan. 11, 2024. He was 79. The Mets said that Harrelson died at a hospice house in East Northport, New York after a long battle with Alzheimer's. AP Photo Golden State Warriors assistant coach Dejan Milojević, a mentor to two-time NBA MVP Nikola Jokic and a former star player in his native Serbia, died Wednesday, Jan. 17, 2024, after suffering a heart attack, the team announced. He was 46. AP Photo/Darren Yamashita, File Jack Burke Jr., the oldest living Masters champion who staged the greatest comeback ever at Augusta National for one of his two majors, died Friday, Jan. 19, 2024, in Houston. He was 100. AP Photo/Paul Vathis, File Mary Weiss, the lead singer of the 1960s pop group the Shangri-Las, whose hits included “The Leader of the Pack,” died Friday, Jan. 19, 2024, in Palm Springs, Calif. She was 75. AP Photo/Jim Cooper, File Norman Jewison, a three-time Oscar nominee who in 1999 received an Academy Award for lifetime achievement, died “peacefully” Saturday, Jan. 20, 2024, according to publicist Jeff Sanderson. He was 97. Chris Pizzello/Invision/AP, File Charles Osgood, who anchored “CBS Sunday Morning” for more than two decades, hosted the long-running radio program “The Osgood File” and was referred to as CBS News’ poet-in-residence, died Tuesday, Jan. 23, 2024. He was 91. AP Photo/Suzanne Plunkett, File Melanie, a singer-songwriter behind 1970s hits including “Brand New Key,” died Tuesday, Jan. 23, 2024. She was 76. Born Melanie Safka, the singer rose through the New York folk scene and was one of only three solo women to perform at Woodstock. Her hits included “Lay Down” and “Look What They've Done to My Song Ma.” AP Photo/Ken Bizzigotti, File Chita Rivera, the dynamic dancer, singer and actress who garnered 10 Tony nominations, winning twice, in a long Broadway career that forged a path for Latina artists, died Tuesday, Jan. 30, 2024. She was 91. Evan Agostini/Invision/AP, File Carl Weathers, a former NFL linebacker who became a Hollywood action movie and comedy star, playing nemesis-turned-ally Apollo Creed in the “Rocky” movies, facing-off against Arnold Schwarzenegger in “Predator” and teaching golf in “Happy Gilmore,” died Thursday, Feb. 1, 2024. He was 76. Richard Shotwell/Invision/AP, File Wayne Kramer, the co-founder of the protopunk Detroit band the MC5 that thrashed out such hardcore anthems as “Kick Out the Jams” and influenced everyone from the Clash to Rage Against the Machine, died Friday, Feb. 2, 2024. at Cedars-Sinai hospital in Los Angeles, according to Jason Heath, a close friend and executive director of Kramer's charity, Jail Guitar Doors. Heath said the cause of death was pancreatic cancer. He was 75. AP Photo/Chris Pizzello, File Actor Ian Lavender, who played a hapless Home Guard soldier in the classic British sitcom “Dad’s Army,” died Monday, Feb. 5, 2024. He was 77. Yui Mok/PA via AP Country music singer-songwriter Toby Keith, whose pro-American anthems were both beloved and criticized, died Monday, Feb. 5, 2024. He was 62. Greg Allen/Invision/AP, File Henry Fambrough, the last surviving original member of the iconic R&B group The Spinners, whose hits included “It’s a Shame,” “Could It Be I’m Falling In Love,” and “The Rubberband Man,” died Wednesday, Feb. 7, 2024, of natural causes, according to a statement from his spokeswoman. He was 85. AP Photo/Carlos Osorio, File Bob Edwards, right, the news anchor many Americans woke up to as founding host of National Public Radio's “Morning Edition” for nearly a quarter-century, died Saturday, Feb. 10, 20243. He was 76. He's shown here with sports announcer Red Barber. AP Photo, File Don Gullett, a former major league pitcher and coach who played for four consecutive World Series champions in the 1970s, died Feb. 14. He was 73. He finished his playing career with a 109-50 record playing for the Cincinnati Reds and New York Yankees. AP File Photo Lefty Driesell, the coach whose folksy drawl belied a fiery on-court demeanor that put Maryland on the college basketball map and enabled him to rebuild several struggling programs, died Feb. 17, 2024, at age 92. AP File Germany players celebrate after Andreas Brehme, left on ground, scores the winning goal in the World Cup soccer final match against Argentina, in the Olympic Stadium, in Rome, July 8, 1990. Andreas Brehme, who scored the only goal as West Germany beat Argentina to win the 1990 World Cup final, died Feb. 20, 2024. He was 63. AP Photo/Carlo Fumagalli, File Despite the effort of Denver Broncos defensive back Steve Foley (43), Dallas Cowboys wide receiver Golden Richards hauls in a touchdown pass during NFL football's Super Bowl 12 in New Orleans on Jan 15, 1978. Richards died Friday, Feb. 23, 2024, of congestive heart failure at his home in Murray, Utah. He was 73. Richards' nephew Lance Richards confirmed his death in a post on his Facebook page. AP File Comedian Richard Lewis attends an NBA basketball game in Los Angeles on Dec. 25, 2012. Lewis, an acclaimed comedian known for exploring his neuroses in frantic, stream-of-consciousness diatribes while dressed in all-black, leading to his nickname “The Prince of Pain,” died Feb. 27, 2024. He was 76. He died at his home in Los Angeles on Tuesday night after suffering a heart attack, according to his publicist Jeff Abraham. Alex Gallardo, Associated Press Former Soviet Prime Minister Nikolai Ryzhkov attends a session of the Federation Council, Russian parliament's upper house, in Moscow, Russia, Wednesday, June 25, 2014. Ryzhkov, former Soviet prime minister who presided over failed efforts to shore up the crumbling economy in the final years before the collapse of the USSR, died Feb. 28, 2024, at age 94. Alexander Zemlianichenko - staff, ASSOCIATED PRESS Brian Mulroney, the former prime minister of Canada, listens during a Senate Foreign Relations Committee hearing on the Canada-U.S.-Mexico relationship, Tuesday, Jan. 30, 2018, on Capitol Hill in Washington. Mulroney died at the age of 84 on Feb. 29, 2024. Jacquelyn Martin Akira Toriyama is pictured in 1982. Toriyama, the creator of one of Japan's best-selling “Dragon Ball” and other popular anime who influenced Japanese comics, died March 1, 2024. He was 68. Uncredited - foreign subscriber, ASSOCIATED PRESS Iris Apfel, a textile expert, interior designer and fashion celebrity known for her eccentric style, died March 1, 2024, at 102. Evan Agostini, Invision/AP Andy Russell, the standout linebacker who was an integral part of the Pittsburgh Steelers’ evolution from perennial losers to champions, died Feb. 29, 2024. He was 82. Russell won two Super Bowls during a 12-year NFL career between 1963-76 that was briefly interrupted by a stint in the military. Russell played in 168 consecutive games and spent 10 years as a team captain. He was named to the Pro Bowl seven times. Russell remained active in the Pittsburgh community after retiring, writing several books and launching the Andy Russell Charitable Foundation. AP photo Pittsburgh Pirates' Ed Ott slides across home late out of reach of Orioles catcher Rick Dempsey to score the winning run in the ninth inning of Game 2 of the World Series at Baltimore, Oct. 11, 1979. Ott, a former major league catcher and coach who helped the Pittsburgh Pirates win the 1979 World Series, died March 3, 2024. He was 72. He batted .259 with 33 homers and 195 RBIs in 567 major league games. Ott and Steve Nicosia were the main catchers when the Pirates won it all in 1979. AP photo In a photo supplied by ESPN, Chris Mortensen appears on the set of Sunday NFL Countdown at ESPN's studios in Bristol, Conn., on Sept. 22, 2019. Mortensen, the award-winning journalist who covered the NFL for close to four decades, including 32 as a senior analyst at ESPN, died March 3, 2024. He was 72. Mortensen announced in 2016 that he he had been diagnosed with throat cancer. Even while undergoing treatment, he was the first to confirm the retirement of Hall of Fame quarterback Peyton Manning. Mortensen announced his retirement after the NFL draft last year so that he could “focus on my health, family and faith.” ESPN via AP Singer Steve Lawrence, left, and his wife Eydie Gorme arrive at a black-tie gala called honoring Frank Sinatra in Las Vegas on May 30, 1998. Lawrence, a singer and top stage act who as a solo performer and in tandem with his wife Gorme kept Tin Pan Alley alive during the rock era, died Wednesday, March 6, 2024 at age 88. Gorme died on Aug. 10, 2013. Lennox McLendon - staff, ASSOCIATED PRESS Martin Luther King III, right, the son of Rev. Martin Luther King Jr., walks with his daughter Yolanda, and Naomi Barber King, left, the wife of Rev. King's brother, A.D., through an exhibition devoted to the awarding of the Nobel Peace Prize to King at the Martin Luther King Jr. Historical Site, Wednesday, Dec. 10, 2014, in Atlanta. Civil rights activist Naomi Barber King died Thursday, March 7, 2024, in Atlanta, according to family members. She was 92. David Goldman - staff, ASSOCIATED PRESS A Texas man who spent decades using an iron lung after contracting polio as a child died March 11, 2024, at the age of 78. Paul Alexander's longtime friend Daniel Spinks says Alexander died Monday at a Dallas hospital. Spinks called his friend one of the "bright stars of the world.” Friends of Alexander, who graduated from law school and had a career as an attorney, say he was a man who had a great joy for life. Alexander was a child when he began using an iron lung, a cylinder that encased his body as the air pressure in the chamber forced air in and out of his lungs. Smiley N. Pool, The Dallas Morning News Astronaut Thomas P. Stafford stands near the NASA Motor Vessel Retriever during training Aug. 23, 1965, in the Gulf of Mexico. Stafford, who commanded a dress rehearsal flight for the 1969 moon landing and the first U.S.-Soviet space linkup, died March 18, 2024, at 93. NASA via AP New York Rangers' Chris Simon celebrates his second-period goal against the New York Islanders, Thursday, Feb. 26, 2004, at Nassau Coliseum in Uniondale, N.Y. Former NHL enforcer Chris Simon has died. He was 52. Simon died March 18, 2024, according to a spokesperson for the NHL Players' Association. ED BETZ - stringer, ASSOCIATED PRESS M. Emmet Walsh arrives at the 2014 Film Independent Spirit Awards, March 1, 2014, in Santa Monica, Calif. Walsh, the character actor who brought his unmistakable face and unsettling presence to films including “Blood Simple” and “Blade Runner,” died March 19, 2024, at age 88, his manager said Wednesday. John Shearer - invision linkable, John Shearer/Invision/AP "Babar" author Laurent de Brunhoff, who revived his father's popular picture book series about an elephant-king, has died at 98 after being in hospice care for two weeks. De Brunhoff was a Paris native who moved to the U.S. in the 1980s. He died March 22, 2024, at his home in Key West, Florida. Just 12 years old when his father, Jean de Brunhoff, died of tuberculosis, Laurent drew upon his own gifts as a painter and storyteller and as an adult released dozens of books about the elephant who reigns over Celesteville, among them "Babar at the Circus" and "Babar's Yoga for Elephants." NATHAN DENETTE, The Canadian Press Longtime Baltimore Orioles owner Peter Angelos has died at the age of 94. His family announced in a statement that Angelos, who had been ill for several years, died March 23, 2024. Angelos was owner of an Orioles team that endured long losing stretches and shrewd proprietor of a law firm that won high-profile cases against industry titans such as tobacco giant Philip Morris. Angelos’ death came as his son, John, was in the process of selling the Orioles to a group headed by Carlyle Group Inc. co-founder David Rubenstein. Peter Angelos purchased the team for $173 million in 1993, at the time the highest for a sports franchise. His public role diminished significantly in his final years. Democratic presidential candidate Al Gore, left, and his running mate, vice presidential candidate Sen. Joe Lieberman of Connecticut, wave to supporters Oct. 25, 2000, at a campaign rally in Jackson, Tenn. Lieberman died March 27, 2024. He was 82 and died Wednesday of complications from a fall. Lieberman nearly won the vice presidency on Democrat Al Gore's ticket in the disputed 2000 White House race. Eight years later, he came close to joining the GOP ticket as John McCain’s running mate. The Democrat-turned-independent stepped down from the Senate in January 2013 after 24 years. His independent streak often irked Senate Democrats he aligned with. Yet his support for gay rights, civil rights, abortion rights and environmental causes at times won him the praise of many liberals over the years. Stephan Savoia, Associated Press Louis Gossett Jr., the first Black man to win a supporting actor Oscar and an Emmy winner for his role in the seminal TV miniseries “Roots,” died March 28, 2024. He was 87. Gossett always thought of his early career as a reverse Cinderella story, with success finding him from an early age and propelling him forward, toward his Academy Award for “An Officer and a Gentleman.” He also was a star on Broadway, replacing Billy Daniels in “Golden Boy” with Sammy Davis Jr. in 1964 and recently played an obstinate patriarch in the 2023 remake of “The Color Purple.” Richard Shotwell Former cast members of SCTV, from left, Dave Thomas, Joe Flaherty, Catherine O'Hara, Andrea Martin, foreground, Harold Ramis, Eugene Levy and Martin Short, pose at the U.S. Comedy Arts Festival on March 6, 1999, in Aspen, Colo. Flaherty, a founding member of the Canadian sketch series “SCTV,” died Monday, April 1, 2024 at age 82. E Pablo Kosmicki - stringer, ASSOCIATED PRESS John Sinclair talks at the John Sinclair Foundation Café and Coffeeshop, Dec. 26, 2018, in Detroit. Sinclair, a poet, music producer and counterculture figure whose lengthy prison sentence after a series of small-time pot busts inspired a John Lennon song and a star-studded 1971 concert to free him, has died at age 82. Sinclair died Tuesday, April 2, 2024 at Detroit Receiving Hospital of congestive heart failure following an illness, his publicist Matt Lee said. Junfu Han - member, ASSOCIATED PRESS Boston Red Sox president Larry Lucchino, right, tips his cap to fans as majority owner John Henry holds the 2013 World Series championship trophy during a parade in celebration of the baseball team's win, Saturday, Nov. 2, 2013, in Boston. Larry Lucchino, the force behind baseball’s retro ballpark revolution and the transformation of the Boston Red Sox from cursed losers to World Series champions, has died. He was 78. Lucchino had suffered from cancer. The Triple-A Worcester Red Sox, his last project in a career that also included three major league baseball franchises and one in the NFL, confirmed his death on Tuesday, April 2, 2024. Charles Krupa - staff, ASSOCIATED PRESS Playwright Christopher Durang appears on stage with producers to accept the award for best play for "Vanya and Sonia and Masha and Spike" at the 67th Annual Tony Awards, on June 9, 2013 in New York. Also on stage are actors, background from left, Shalita Grant, Kristine Nielsen and Billy Magnussen. Durang died Tuesday, April 2, 2024, at his home in Pipersville, Pennsylvania, of complications from logopenic primary progressive aphasia. He was 75. Evan Agostini - invision linkable, Evan Agostini/Invision/AP In this Oct. 16, 1969 file photo, New York Mets catcher Jerry Grote, right, embraces pitcher Jerry Koosman as Ed Charles, left, joins the celebration after the Mets defeated the Baltimore Orioles in the Game 5 to win the baseball World Series at New York's Shea Stadium. Grote, the catcher who helped transform the New York Mets from a perennial loser into the 1969 World Series champion, died Sunday, April 7, 2024. He was 81. AP Photo, File In this July 8, 2003 photo, Lori, left, and George Schappell, conjoined twins, are photographed in their Reading, Pa., apartment. Lori and George Schappell, who pursued separate careers, interests and relationships during lives that defied medical expectations, died April 7, 2024, at the Hospital of the University of Pennsylvania. They were 62. (John A. Secoges/Reading Eagle via AP, File The University of Edinburgh says Nobel prize-winning physicist Peter Higgs, who proposed the existence of a sub-atomic particle that came to be known as the Higgs boson, died April 8, 2024, at 94. Higgs predicted the existence of the particle in 1964. But it would be almost 50 years before the its existence could be confirmed at a particle collider in Switzerland called the Large Hadron Collider. Higgs’ work helps scientists understand of the most fundamental riddles of the universe: how the Big Bang created something out of nothing 13.7 billion years ago. Higgs won the 2013 Nobel Prize in Physics for his work, alongside Francois Englert of Belgium. Scott Heppell, Associated Press A retired U.S. Army colonel who was awarded the Medal of Honor for heroism during the Korean War died April 8, 2024, at age 97. A funeral home says that Ralph Puckett Jr. died Monday at his home in Columbus, Georgia. President Joe Biden presented Puckett with the Medal of Honor in 2021, more than seven decades after Puckett was seriously wounded leading an outnumbered company of Army Rangers in battle. Puckett refused a medical discharge and served as an Army officer for another 20 years before retiring in 1971. Puckett received the U.S. military's highest honor from President Joe Biden on May 21, 2021, following a policy change that lifted a requirement for medals to be given within five years of a valorous act. Alex Brandon, Associated Press O.J. Simpson, left, grimaces June 15, 1995, in a Los Angeles courtroom as he famously tries on one of the leather gloves prosecutors say he wore the night his ex-wife Nicole Brown Simpson and Ron Goldman were murdered. Simpson, t he decorated football star who was acquitted of charges he killed his former wife and her friend but wound up in prison years later in an unrelated case, died April 10, 2024. He was 76. His family made an announcement Thursday in a statement on Simpson's X account. Simpson said last year that he was battling prostate cancer. Simpson’s gridiron legacy was forever overshadowed by the 1994 knife slayings of Brown Simpson and Goldman. A criminal court jury found him not guilty of murder, but a separate civil trial jury found him liable. Simpson's nine-year prison stint in Nevada was for the armed robbery of two sports memorabilia dealers. Sam Mircovich, Associated Press Francis Coppola and wife, Eleanor, pose July 16, 1991, in Los Angeles. Eleanor Coppola, who documented the making of some of her husband Francis Ford Coppola’s iconic films, including the infamously tortured production of “Apocalypse Now,” and who raised a family of filmmakers, has died. She was 87. Coppola died April 12, 2024, at home in Rutherford, California, her family announced in a statement. Eleanor, who grew in Orange County, California, met Francis while working as an assistant art director on his directorial debut, the Roger Corman-produced 1963 horror film “Dementia 13.” Their first-born, Gian-Carlo, quickly became a regular presence in his father’s films, as did their subsequent children, Roman, and Sofia. After acting in their father’s films and growing up on sets, all would go into the movies. Chris Martinez - staff, ASSOCIATED PRESS Robert MacNeil, seen in February 1978, who created the even-handed, no-frills PBS newscast “The MacNeil-Lehrer NewsHour” in the 1970s and co-anchored the show for with his late partner, Jim Lehrer, for two decades, died April 12, 2024, at age 93. Associated Press Artist Faith Ringgold poses for a portrait in front of a painted self-portrait during a press preview of her exhibition, "American People, Black Light: Faith Ringgold's Paintings of the 1960s" at the National Museum of Women in the Arts in Washington, June 19, 2013. Ringgold, an award-winning author and artist who broke down barriers for Black female artists and became famous for her richly colored and detailed quilts combining painting, textiles and storytelling, died Friday, April 12, 2024, at her home in Englewood, N.J. She was 93. Jacquelyn Martin - staff, ASSOCIATED PRESS Alabama coach Bear Bryant, left, talks with his former star quarterback Steve Sloan, right, after practice in Miami for the Orange Bowl game New Years' night against Nebraska, Dec. 29, 1968. Former college coach and administrator Sloan, who played quarterback and served as athletic director at Alabama. has passed away. He was 79. Sloan died Sunday, April 14, 2024, after three months of memory care at Orlando Health Dr. P. Phillips Hospital, according to an obituary from former Alabama sports information director Wayne Atcheson. Harold Valentine - staff, ASSOCIATED PRESS Oakland A's pitcher Ken Holtzman poses for a photo in March 1975. Holtzman, who pitched two no-hitters for the Chicago Cubs and helped the Oakland Athletics win three straight World Series championships in the 1970s, died April 14, 2024. He finished with a career record of 174-150 over 15 season with four teams and was the winningest Jewish pitcher in baseball history. Robert H. Houston - staff, ASSOCIATED PRESS Carl Erskine, center, pictured with teammate Duke Snider, left, and manager Charley Dressen in 1952, after beating the Yankees 6-5 in Game 5 of the World Series at Yankee Stadium in New York, Oct. 5, 1952. Erskine, who pitched two no-hitters for the Brooklyn Dodgers and was a 20-game winner in 1953 when he struck out a then-record 14 in the World Series, has died. Among the last survivors from the celebrated Brooklyn teams of the 1950s, Erskine spent his entire major league career with the Dodgers. He helped them win five National League pennants from 1948-59. Erskine won Game 3 of the 1953 World Series, beating the Yankees 3-2. He appeared in five World Series, with the Dodgers beating the Yankees in 1955 for their only championship in Brooklyn. Erksine died April 16 in his hometown of Anderson, Indiana, according to a hospital official. He was 97. AP photo St. Louis Cardinals manager Whitey Herzog lets umpire John Shulock, right, know how he feels about Shulock's call on the tag attempt on Kansas City Royals Jim Sundberg by Cardinals catcher Tom Nieto, second from left, in the second inning of Game 5 of the 1985 World Series in St. Louis. Herzog, the gruff and ingenious Hall of Fame manager who guided the St. Louis Cardinals to three pennants and a World Series title and perfected an intricate, nail-biting strategy known as “Whiteyball,” has died. Herzog, affectionately nicknamed “The White Rat,” was a manager for 18 seasons, compiling an overall record of 1,281 wins and 1,125 losses. He was named Manager of the Year in 1985. Under Herzog, the Cardinals won pennants in 1982, 1985 and 1987 and won the World Series in 1982, when they edged the Milwaukee Brewers in seven games. He died April 15, 2024, and was 92. AP File Photo Senate Intelligence Committee Chairman Sen. Bob Graham, D-Fla., gestures as he answers questions regarding the ongoing security hearing on Capitol Hill, June 18, 2002, in Washington. Graham, who chaired the Intelligence Committee following the 2001 terrorist attacks and opposed the Iraq invasion, died April 16, 2024. He was 87. His family announced the death Tuesday in a statement posted on X by his daughter Gwen Graham. Graham served three terms in the Senate and two terms as Florida's governor. He made an unsuccessful bid for the 2004 Democratic presidential nomination, emphasizing his opposition to the Iraq invasion. But that bid was delayed by heart surgery in January 2003, and he was never able to gain enough traction with voters to catch up. He didn’t seek re-election in 2004 and was replaced by Republican Mel Martinez. PABLO MARTINEZ MONSIVAIS - staff, ASSOCIATED PRESS Guitar legend and Allman Brothers Band co-founder Dickey Betts died April 18, 2024, at age 80. The Rock & Roll Hall of Famer wrote the band's biggest hit, “Ramblin’ Man.” Manager David Spero told The Associated Press that Betts died early Thursday at his home in Osprey, Florida. He says Betts had been battling cancer for more than a year and had chronic obstructive pulmonary disease. Betts shared lead guitar duties with Duane Allman in the original Allman Brothers Band to help give the group its distinctive sound and create a new genre: Southern rock. Acts ranging from Lynyrd Skynyrd to Kid Rock were influenced by the Allmans’ music, which combined blues, country, R&B and jazz with ’60s rock. Jason Vorhees, The Macon Telegraph via AP Contemporary Christian singer Mandisa, who appeared on “American Idol” and won a Grammy for her 2013 album “Overcomer,” died April 18, 2024. She was 47. Mandisa gained stardom after finishing ninth on “American Idol” in 2006. In 2014, she won a Grammy for best contemporary Christian music album for “Overcomer,” her fifth album. She spoke openly about her struggles with depression, releasing a memoir that detailed her experiences with severe depression, weight-related challenges, the coronavirus pandemic and her faith. Mark Humphrey, Associated Press David Pryor, a former Arkansas governor and U.S. senator who was one of the state’s most beloved and active political figures, died April 20, 2024, at the age of 89. His son, former two-term Democratic U.S. Sen. Mark Pryor, says the Democrat died Saturday of natural causes in Little Rock surrounded by family. David Pryor was considered one of the Democratic party’s giants in Arkansas and remained active in public life after he left office, including serving on the University of Arkansas’s Board of Trustees. DANNY JOHNSTON - staff, ASSOCIATED PRESS Roman Gabriel was known for his big size and big arm. He was the first Filipino-American quarterback in the NFL. And he still holds the Los Angeles Rams record for touchdown passes. Gabriel died April 20, 2024, at age 83. His son posted the news on social media. He says Gabriel died at home of natural causes. Gabriel starred at North Carolina State and was the No. 2 pick by the Rams in the 1962 draft. The Oakland Raider of the rival AFL made him the No. 1 pick. Gabriel signed with the Rams and later played with the Philadelphia Eagles. Rusty Kennedy - staff, ASSOCIATED PRESS Andrew Davis, an acclaimed British conductor who was music director of the Lyric Opera of Chicago and orchestras on three continents, died April 20, 2024. He was 80. Davis died Saturday at Rusk Institute in Chicago from leukemia. That is according to his manager, Jonathan Brill of Opus 3 Artists. Davis had been managing the disease for 1 1/2 to 2 years but it became acute shortly after his 80th birthday on Feb. 2. Davis was music director of the Toronto Symphony Orchestra from 1975-88, Britain’s Glyndebourne Festival from 1988-2000, chief conductor of the BBC Symphony Orchestra from 1989-2000, then was music director of the Lyric Opera from 2000-21. Richard Drew - staff, ASSOCIATED PRESS Former hostage Terry Anderson waves to the crowd as he rides in a parade in Lorain, Ohio, June 22, 1992. Anderson, the globe-trotting Associated Press correspondent who became one of America’s longest-held hostages, died April 21, 2024. Anderson was snatched from a street in war-torn Lebanon in 1985 and held for nearly seven years. Anderson, who was tortured and chained to a wall, wrote about his experiences in the best-selling memoir, “Den of Lions.” After returning to the United States in 1991, Anderson gave public speeches, taught journalism and, at various times, operated a blues bar, Cajun restaurant, horse ranch and gourmet restaurant. He also struggled with post-traumatic stress disorder. Mark Duncan - staff, ASSOCIATED PRESS British army veteran Bill Gladden, who survived a glider landing on D-Day and a bullet that tore through his ankle a few days later, wanted to return to France for the 80th anniversary of the invasion so he could honor the men who didn’t come home. It was not to be. Gladden, one of the dwindling number of veterans who took part in the landings that kicked off the campaign to liberate Western Europe from the Nazis during World War II, died April 24, his family said. He was 100. With fewer and fewer veterans taking part each year, the ceremony may be one of the last big events marking the assault that began on June 6, 1944. Thomas Padilla, Associated Press Duane Eddy, a pioneering guitar hero whose reverberating electric sound on instrumentals such as “Rebel Rouser,” “Forty Miles of Bad Road" and “Cannonball” helped put the twang in early rock ‘n’ roll and influenced George Harrison, Bruce Springsteen and countless other musicians, died April 30 at age 86. With his raucous rhythms, and backing hollers and hand claps, Eddy sold more than 100 million records worldwide, and mastered a distinctive sound based on the premise that a guitar’s bass strings sounded better on tape than the high ones. Chris Pizzello, Invision/AP, File Author Paul Auster has died at age 77. Auster was a prolific, prize-winning man of letters and filmmaker known for such inventive narratives and meta-narratives as “The New York Trilogy” and “4 3 2 1." Auster’s death on April 30 was confirmed by his literary representatives. Auster completed more than 30 books, translated into dozens of languages. He never achieved major commercial success in the U.S., but he was widely admired overseas for his cosmopolitan worldview and erudite and introspective style. Auster’s novels were a mix of history, politics, genre experiments, existential quests and self-conscious references to writers and writing. Bebeto Matthews - staff, ASSOCIATED PRESS Co-pilots Dick Rutan, right, and Jeana Yeager, no relationship to test pilot Chuck Yeager, pose for a photo after a test flight over the Mojave Desert, Dec. 19, 1985. Rutan, a decorated Vietnam War pilot, who along with copilot Yeager completed one of the greatest milestones in aviation history: the first round-the-world flight with no stops or refueling, died late Friday, May 3, 2024. He was 85. Doug Pizac - staff, ASSOCIATED PRESS Music producer Steve Albini, seen in his Chicago studio in 2014, produced albums by Nirvana, the Pixies and PJ Harvey. Albini died at 61. Brian Fox, an engineer at Albini’s studio, Electrical Audio, says Albini died after a heart attack May 7. In addition to his work on canonized rock albums such as Nirvana‘s “In Utero,” the Pixies’ breakthrough “Surfer Rosa,” and PJ Harvey’s “Rid of Me,” Albini was the frontman of the underground bands Big Black and Shellac. He dismissed the term “producer” and requested he be credited with “Recorded by Steve Albini." Brian Cassella, Chicago Tribune San Francisco 49ers Hall of Fame football player Jimmy Johnson, left, is honored by owner Jed York before a 2011 game between against the St. Louis Rams in San Francisco. Pro Football Hall of Fame defensive back Jimmy Johnson, a three-time All-Pro and member of the All-Decade Team of the 1970s, has died. He was 86. Johnson's family told the Pro Football Hall of Fame that he died May 8. Johnson was inducted into the Hall of Fame in 1994. He played his entire 16-year pro career with San Francisco. He played in 213 games, more than any other 49ers player at the time of his retirement. AP File Photo San Diego Padres third baseman Sean Burroughs fires a throw to first from his knees but is unable to get Los Angeles Dodgers' D. J. Houlton at first during the third inning of a baseball game June 22, 2005, in San Diego. Burroughs, a two-time Little League World Series champion who won an Olympic gold medal and went on to a major league career that was interrupted by substance abuse, has died. He was 43. The Los Angeles County Medical Examiner’s online records said Burroughs died Thursday, May 9, 2024, with the cause of death deferred. LENNY IGNELZI Producer Roger Corman poses in his Los Angeles office, May 8, 2013. Corman, the Oscar-winning “King of the Bs” who helped turn out such low-budget classics as “Little Shop of Horrors” and “Attack of the Crab Monsters” and gave many of Hollywood's most famous actors and directors an early break, died Thursday, May 9, 2024. He was 98. Reed Saxon - staff, ASSOCIATED PRESS A.J. Smith, a longtime NFL executive who was the winningest general manager in Chargers history, has died. He was 75. His son, Atlanta assistant general manager Kyle Smith, announced in a statement released by the Falcons that his father died May 12. Kyle Smith said his father had been battling prostate cancer for seven years. The Chargers won five division titles during Smith’s 10 seasons as GM. The franchise’s 98 wins, including the playoffs, were the sixth most in the league from 2003-12. LENNY IGNELZI Saxophone player David Sanborn performs during his concert at the Stravinski hall at the "Colours of Music night" during the 34th Montreux Jazz Festival in Montreux, Switzerland on July 10, 2000. Sanborn, the Grammy-winning saxophonist who played lively solos on such hits as David Bowie's “Young Americans” and James Taylor's “How Sweet It Is (To Be Loved By You)” and enjoyed his own highly successful recording career as a leading performer of contemporary jazz, died Sunday, May 12, 2024, at age 78. Laurent Gillieron - foreign subscriber, ASSOCIATED PRESS Nobel laureate Alice Munro has died. The Canadian literary giant who became one of the world’s most esteemed contemporary authors and one of history’s most honored short story writers was 92. Munro achieved stature rare for an art form traditionally placed beneath the novel. She was the first lifelong Canadian to win the Nobel and the first recipient cited exclusively for short fiction. Munro was little known beyond Canada until her late 30s but became one of the few short story writers to enjoy ongoing commercial success. A spokesperson for publisher Penguin Random House Canada said Munro died May 13 at home in Port Hope, Ontario. Paul Hawthorne - staff, ASSOCIATED PRESS Dabney Coleman, the mustachioed character actor who specialized in smarmy villains like the chauvinist boss in “9 to 5” and the nasty TV director in “Tootsie,” died May 16. He was 92. For two decades Coleman labored in movies and TV shows as a talented but largely unnoticed performer. That changed abruptly in 1976 when he was cast as the incorrigibly corrupt mayor of the hamlet of Fernwood in “Mary Hartman, Mary Hartman,” a satirical soap opera. He won a Golden Globe for “The Slap Maxwell Story” and an Emmy Award for best supporting actor in Peter Levin’s 1987 small screen legal drama “Sworn to Silence.” Nick Ut, Associated Press Iranian President Ebrahim Raisi listens to Turkish President Recep Tayyip Erdogan, not in photo, during a joint news conference following their meeting at the Presidential palace in Ankara, Turkey, Jan. 24, 2024. Iran’s President Ebrahim Raisi, foreign minister Hossein Amirabdollahian and others were found dead at the site of a helicopter crash site, state media reported Monday, May 20, 2024. Mert Gokhan Koc - foreign subscriber, ASSOCIATED PRESS Jim Otto, the Hall of Fame center known as Mr. Raider for his durability through a litany of injuries, died May 19. He was 86. The cause of death was not immediately known. Otto joined the Raiders for their inaugural season in the American Football League in 1960 and was a fixture on the team for the next 15 years. He never missed a game because of injuries and competed in 210 consecutive regular-season games and 308 straight total contests despite undergoing nine operations on his knees during his playing career. His right leg was amputated in 2007. AP File Photo Ivan F. Boesky, the flamboyant stock trader whose cooperation with the government cracked open one of the largest insider trading scandals on Wall Street, has died at the age of 87. A representative at the Marianne Boesky Gallery, owned by his daughter, confirmed his death. The son of a Detroit delicatessen owner, Boesky was once considered one of the richest and most influential risk-takers on Wall Street. He had parlayed $700,000 from his late mother-in-law’s estate into a fortune estimated at more than $200 million. Once implicated in insider trading, Boesky cooperated with a brash young U.S. attorney named Rudolph Giuliani, uncovering a scandal that blemished some of the most respected U.S. investment brokerages. Boesky died May 20. G. Paul Burnett - staff, ASSOCIATED PRESS Jan. A.P. Kaczmarek poses with the Oscar for best original score for his work on "Finding Neverland" during the 77th Academy Awards, Feb. 27, 2005, in Los Angeles. Polish composer Kaczmarek, who won a 2005 Oscar for the movie “Finding Neverland,” has died on Tuesday, May 21, 2024, at age 71. Kaczmarek’s death was announced by Poland’s Music Foundation. Reed Saxon - staff, ASSOCIATED PRESS Train bassist and founding member Charlie Colin has died at 58. Colin’s sister confirmed the musician's death Wednesday to The Associated Press. Variety reported Colin slipped and fell in the shower while house-sitting for a friend in Brussels. Train formed in San Francisco in the early ’90s. Colin played on Train's first three records, 1998’s self-titled album, 2001’s “Drops of Jupiter” and 2003’s “My Private Nation.” The track “Drops of Jupiter (Tell Me)” hit No. 5 on the Billboard Hot 100. It also earned two Grammys. Colin left the band in 2003. He also worked with the Newport Beach Film Festival. Colin died May 22. Richard Shotwell - invision linkable, Richard Shotwell/Invision/AP Documentary filmmaker Morgan Spurlock, an Oscar nominee whose most famous works skewered America’s food industry and who notably ate only at McDonald’s for a month to illustrate the dangers of a fast-food diet, has died of cancer. He was 53. Spurlock made a splash in 2004 with his groundbreaking film “Super Size Me,” and returned in 2019 with “Super Size Me 2: Holy Chicken!” — a sober look at an industry that processes 9 billion animals a year in America. Spurlock was a gonzo-like filmmaker who leaned into the bizarre and ridiculous. His stylistic touches included zippy graphics and amusing music. Spurlock died May 23. MARK J. TERRILL, Associated Press Richard M. Sherman, one half of the prolific, award-winning pair of brothers who helped form millions of childhoods by penning classic Disney tunes, has died. He was 95. Sherman, along with his late brother Robert, wrote hundreds of songs together, including songs for “Mary Poppins,” “The Jungle Book” and “Chitty Chitty Bang Bang” — as well as the most-played tune on Earth, “It’s a Small World (After All).” The Walt Disney Co. announced that Sherman died Saturday due to age-related illness. The brothers won two Academy Awards for Walt Disney’s 1964 smash “Mary Poppins.” Robert Sherman died May 25 in London in 2012. Willy Sanjuan, Invision Basketball Hall of Fame legend Bill Walton laughs during a practice session for the NBA All-Star basketball game in Cleveland, Feb. 19, 2022. Walton, who starred for John Wooden's UCLA Bruins before becoming a Basketball Hall of Famer and one of the biggest stars of basketball broadcasting, died Monday, May 27, 2024, the league announced on behalf of his family. He was 71. Charles Krupa - staff, ASSOCIATED PRESS “The Godfather” producer Albert S. Ruddy died May 25 at 94. The Canadian-born producer and writer won Oscars for “The Godfather” and “Million Dollar Baby,” developed the raucous prison-sports comedy “The Longest Yard” and helped create the hit sitcom “Hogan’s Heroes." A spokesperson says Ruddy died Saturday at the UCLA Medical Center. Ruddy produced more than 30 movies and was on hand for the very top and the very bottom. “The Godfather” and “Million Dollar Baby” were box office hits and winners of best picture Oscars. But Ruddy also helped give us “Cannonball Run II” and “Megaforce,” nominees for Golden Raspberry awards for worst movie of the year. Associated Press Larry Allen, one of the most dominant offensive linemen in the NFL during a 12-year career spent mostly with the Dallas Cowboys, died June 2. He was 52. The Cowboys say Allen died suddenly on Sunday while on vacation with his family in Mexico. Allen was named an All-Pro six consecutive years from 1996-2001 and was inducted into the Pro Football of Hall of Fame in 2013. He said few words but let his blocking do the talking. Allen once bench-pressed 700 pounds and had the speed to chase down opposing running backs. Irwin Thompson, The Dallas Morning News via AP Bob Hope and Janis Paige hug during the annual Christmas show in Saigon, Vietnam, Dec. 25, 1964. Paige, a popular actor in Hollywood and in Broadway musicals and comedies who danced with Fred Astaire, toured with Bob Hope and continued to perform into her 80s, died Sunday, June 2, 2024, of natural causes at her Los Angeles home, longtime friend Stuart Lampert said Monday, June 3. Anonymous - staff, ASSOCIATED PRESS Parnelli Jones, the 1963 Indianapolis 500 winner, died June 4 at Torrance Memorial Medical Center after a battle with Parkinson’s disease, his son said. Jones was 90. At the time of his death, Jones was the oldest living winner of “The Greatest Spectacle in Racing.” Rufus Parnell Jones was born in Texarkana, Arkansas, in 1933 but moved to Torrance as a young child and never left. It was there that he became “Parnelli” because his given name of Rufus was too well known for him to compete without locals knowing that he wasn’t old enough to race. AP File Photo Boston Celtics' John Havlicek (17) is defended by Philadelphia 76ers' Chet Walker (25) during the first half of an NBA basketball playoff game April 14, 1968, in Boston. Walker, a seven-time All-Star forward who helped Wilt Chamberlain and the 76ers win the 1967 NBA title, died June 8. He was 84. The National Basketball Players Association confirmed Walker's death, according to NBA.com . The 76ers, Chicago Bulls and National Basketball Retired Players Association also extended their condolences on social media on Saturday, June 8, 2024. A.E. Maloof, Associated Press The Rev. James Lawson Jr. speaks Sept. 17, 2015, in Murfreesboro, Tenn. Lawson Jr., an apostle of nonviolent protest who schooled activists to withstand brutal reactions from white authorities as the Civil Rights Movement gained traction, has died, his family said Monday. He was 95. His family said Lawson died on Sunday after a short illness in Los Angeles, where he spent decades working as a pastor, labor movement organizer and university professor. Lawson was a close adviser to the Rev. Martin Luther King Jr., who called him “the leading theorist and strategist of nonviolence in the world.” Lawson met King in 1957, after spending three years in India soaking up knowledge about Mohandas K. Gandhi’s independence movement. King would travel to India himself two years later, but at the time, he had only read about Gandhi in books. Mark Humphrey, Associated Press Basketball Hall of Fame inductee Jerry West, representing the 1960 USA Olympic Team, is seen Aug. 13, 2010, during the enshrinement news conference at the Hall of Fame Museum in Springfield, Mass. Jerry West, who was selected to the Basketball Hall of Fame three times in a storied career as a player and executive, and whose silhouette is considered to be the basis of the NBA logo, died June 12, the Los Angeles Clippers announced. He was 86. West, nicknamed “Mr. Clutch” for his late-game exploits as a player, was an NBA champion who went into the Hall of Fame as a player in 1980 and again as a member of the gold medal-winning 1960 U.S. Olympic Team in 2010. He will be enshrined for a third time later this year as a contributor, and NBA Commissioner Adam Silver called West “one of the greatest executives in sports history.” Elise Amendola, Associated Press Actor and director Ron Simons, seen Jan. 23, 2011, during the 2011 Sundance Film Festival, died June 12. Simons turned into a formidable screen and stage producer, winning four Tony Awards and having several films selected at the Sundance Film Festival. He won Tonys for producing “Porgy and Bess,” “A Gentleman’s Guide to Love and Murder,” “Vanya and Sonia and Masha and Spike,” and “Jitney.” He also co-produced “Hughie,” with Forest Whitaker, “The Gin Game,” starring Cicely Tyson and James Earl Jones, “Ain’t Too Proud: The Life and Times of The Temptations,” an all-Black production of “A Streetcar Named Desire,” the revival of "for colored girls who have considered suicide/when the rainbow is enuf" and the original work “Thoughts of a Colored Man.” He was in the films “27 Dresses” and “Mystery Team,” as well as on the small screen in “The Resident,” “Law & Order,” “Law & Order: Criminal Intent” and “Law & Order: SVU.” Victoria Will, Associated Press Bob Schul of West Milton, Ohio, hits the tape Oct. 18, 1964, to win the 5,000 meter run at the Olympic Games in Tokyo. Schul, the only American distance runner to win the 5,000 meters at the Olympics, died June 16. He was 86. His death was announced by Miami University in Ohio , where Schul shined on the track and was inducted into the school’s hall of fame in 1973. Schul predicted gold leading into the 1964 Tokyo Olympics and followed through with his promise. On a rainy day in Japan, he finished the final lap in a blistering 54.8 seconds to sprint to the win. His white shorts were covered in mud at the finish. He was inducted into the USA Track and Field Hall of Fame in 1991. He also helped write a book called “In the Long Run.” Associated Press San Francisco Giants superstar Willie Mays poses for a photo during baseball spring training in 1972. Mays, the electrifying “Say Hey Kid” whose singular combination of talent, drive and exuberance made him one of baseball’s greatest and most beloved players, died June 18. He was 93. The center fielder, who began his professional career in the Negro Leagues in 1948, had been baseball’s oldest living Hall of Famer. He was voted into the Hall in 1979, his first year of eligibility, and in 1999 followed only Babe Ruth on The Sporting News’ list of the game’s top stars. The Giants retired his uniform number, 24, and set their AT&T Park in San Francisco on Willie Mays Plaza. Mays died two days before a game between the Giants and St. Louis Cardinals to honor the Negro Leagues at Rickwood Field in Birmingham , Alabama. Over 23 major league seasons, virtually all with the New York/San Francisco Giants but also including one in the Negro Leagues, Mays batted .301, hit 660 home runs, totaled 3,293 hits, scored more than 2,000 runs and won 12 Gold Gloves. He was Rookie of the Year in 1951, twice was named the Most Valuable Player and finished in the top 10 for the MVP 10 other times. His lightning sprint and over-the-shoulder grab of an apparent extra base hit in the 1954 World Series remains the most celebrated defensive play in baseball history. For millions in the 1950s and ’60s and after, the smiling ballplayer with the friendly, high-pitched voice was a signature athlete and showman during an era when baseball was still the signature pastime. Awarded the Medal of Freedom by President Barack Obama in 2015, Mays left his fans with countless memories. But a single feat served to capture his magic — one so untoppable it was simply called “The Catch.” Associated Press Actor Donald Sutherland appears Oct. 13, 2017, at the Academy of Motion Picture Arts and Sciences in Beverly Hills, Calif. Sutherland, the Canadian actor whose wry, arrestingly off-kilter screen presence spanned more than half a century of films from “M.A.S.H.” to “The Hunger Games,” died June 20. He was 88. Kiefer Sutherland said on X he believed his father was one of the most important actors in the history of film: “Never daunted by a role, good, bad or ugly. He loved what he did and did what he loved, and one can never ask for more than that.” The tall and gaunt Sutherland, who flashed a grin that could be sweet or diabolical, was known for offbeat characters like Hawkeye Pierce in Robert Altman's "M.A.S.H.," the hippie tank commander in "Kelly's Heroes" and the stoned professor in "Animal House." Before transitioning into a long career as a respected character actor, Sutherland epitomized the unpredictable, antiestablishment cinema of the 1970s. He never stopped working, appearing in nearly 200 films and series. Over the decades, Sutherland showed his range in more buttoned-down — but still eccentric — roles in Robert Redford's "Ordinary People" and Oliver Stone's "JFK." More, recently, he starred in the “Hunger Games” films. A memoir, “Made Up, But Still True,” is due out in November. Chris Pizzello, Associated Press Actor Bill Cobbs, a cast member in "Get Low," arrives July 27, 2010, at the premiere of the film in Beverly Hills, Calif. Cobbs, the veteran character actor who became a ubiquitous and sage screen presence as an older man, died June 25. He was 90. A Cleveland native, Cobbs acted in such films as “The Hudsucker Proxy,” “The Bodyguard” and “Night at the Museum.” He made his first big-screen appearance in a fleeting role in 1974's “The Taking of Pelham One Two Three." He became a lifelong actor with some 200 film and TV credits. The lion share of those came in his 50s, 60s, and 70s, as filmmakers and TV producers turned to him again and again to imbue small but pivotal parts with a wizened and worn soulfulness. Cobbs appeared on television shows including “The Sopranos," “The West Wing,” “Sesame Street” and “Good Times.” He was Whitney Houston's manager in “The Bodyguard” (1992), the mystical clock man of the Coen brothers' “The Hudsucker Proxy” (1994) and the doctor of John Sayles' “Sunshine State” (2002). He played the coach in “Air Bud” (1997), the security guard in “Night at the Museum” (2006) and the father on “The Gregory Hines Show." Cobbs rarely got the kinds of major parts that stand out and win awards. Instead, Cobbs was a familiar and memorable everyman who left an impression on audiences, regardless of screen time. He won a Daytime Emmy Award for outstanding limited performance in a daytime program for the series “Dino Dana” in 2020. Chris Pizzello, Associated Press Independent gubernatorial candidate Kinky Friedman speaks with the media Nov. 7, 2009, at his campaign headquarters in Austin, Texas. The singer, songwriter, satirist and novelist, who led the alt-country band Texas Jewboys, toured with Bob Dylan, sang with Willie Nelson, and dabbled in politics with campaigns for Texas governor and other statewide offices, died June 27. He was 79 and had suffered from Parkinson's disease. Often called “The Kinkster" and sporting sideburns, a thick mustache and cowboy hat, Friedman earned a cult following and reputation as a provocateur throughout his career across musical and literary genres. In the 1970s, his satirical country band Kinky Friedman and the Texas Jewboys wrote songs with titles such as “They Ain't Makin' Jews Like Jesus Anymore” and “Get Your Biscuits in the Oven and Your Buns in Bed.” Friedman joined part of Bob Dylan's Rolling Thunder Revue tour in 1976. By the 1980s, Friedman was writing crime novels that often included a version of himself, and he wrote a column for Texas Monthly magazine in the 2000s. Friedman's run at politics brought his brand of irreverence to the serious world of public policy. In 2006, Friedman ran for governor as an independent in a five-way race that included incumbent Republican Rick Perry. Friedman launched his campaign against the backdrop of the Alamo. Eric Gay, Associated Press Martin Mull participates in "The Cool Kids" panel during the Fox Television Critics Association Summer Press Tour on Aug. 2, 2018, at The Beverly Hilton hotel in Beverly Hills, Calif. Mull, whose droll, esoteric comedy and acting made him a hip sensation in the 1970s and later a beloved guest star on sitcoms including “Roseanne” and “Arrested Development,” died June 28. He was 80. Mull, who was also a guitarist and painter, came to national fame with a recurring role on the Norman Lear-created satirical soap opera “Mary Hartman, Mary Hartman,” and the starring role in its spinoff, “Fernwood Tonight." His first foray into show business was as a songwriter, penning the 1970 semi-hit “A Girl Named Johnny Cash” for singer Jane Morgan. He would combine music and comedy in an act that he brought to hip Hollywood clubs in the 1970s. Mull often played slightly sleazy, somewhat slimy and often smarmy characters as he did as Teri Garr's boss and Michael Keaton's foe in 1983's “Mr. Mom.” He played Colonel Mustard in the 1985 movie adaptation of the board game “Clue,” which, like many things Mull appeared in, has become a cult classic. The 1980s also brought what many thought was his best work, “A History of White People in America,” a mockumentary that first aired on Cinemax. Mull co-created the show and starred as a “60 Minutes” style investigative reporter investigating all things milquetoast and mundane. Willard was again a co-star. In the 1990s he was best known for his recurring role on several seasons on “Roseanne,” in which he played a warmer, less sleazy boss to the title character, an openly gay man whose partner was played by Willard, who died in 2020 . Mull would later play private eye Gene Parmesan on “Arrested Development,” a cult-classic character on a cult-classic show, and would be nominated for an Emmy, his first, in 2016 for a guest run on “Veep.” Willy Sanjuan, Invision Screenwriter Robert Towne poses at The Regency Hotel, March 7, 2006, in New York. Towne, the Oscar-winning screenplay writer of "Shampoo," "The Last Detail" and other acclaimed films whose work on "Chinatown" became a model of the art form and helped define the jaded allure of his native Los Angeles, died Monday, July 1, 2024, surrounded by family at his home in Los Angeles, said publicist Carri McClure. She declined to comment on any cause of death. Jim Cooper - stringer, ASSOCIATED PRESS Vic Seixas of the United States backhands a volley from Denmark's Jurgen Ulrich in the first round of men's singles match at Wimbledon, England, June 27, 1967. Vic Seixas, a Wimbledon winner and tennis Hall of Famer who was the oldest living Grand Slam champion, has died July 5 at the age of 100. The International Tennis Hall of Fame announced Seixas’ death on Saturday July 6, 2024, based on confirmation from his daughter Tori. AP Photo/File In this June 30, 2020, file photo, Sen. James Inhofe, R-Okla., speaks to reporters following a GOP policy meeting on Capitol Hill in Washington. Former Sen. Jim Inhofe of Oklahoma died July 9. He was 89. The family says in a statement that the Republican had a stroke during the July Fourth holiday and died Tuesday morning. Inhofe was a powerful fixture in state politics for decades. He doubted that climate change was caused by human activity, calling the theory “the greatest hoax ever perpetrated on the American people.” As Oklahoma’s senior U.S. senator, he was a staunch supporter of the state’s military installations. He was elected to a fifth Senate term in 2020 and stepped down in early 2023. Manuel Balce Ceneta The Oak Ridge Boys, from left, Joe Bonsall, Richard Sterban, Duane Allen and William Lee Golden hold their awards for Top Vocal Group and Best Album of the Year for "Ya'll Come Back Saloon", during the 14th Annual Academy of Country Music Awards in Los Angeles, Calif., May 3, 1979. Bonsall died on July 9, 2024, from complications of Amyotrophic Lateral Sclerosis in Hendersonville, Tenn. He was 76. A Philadelphia native and resident of Hendersonville, Tennessee, Bonsall joined the Oak Ridge Boys in 1973, which originally formed in the 1940s. He saw the band through its golden period in the '80s and beyond, which included their signature 1981 song “Elvira.” The hit marked a massive crossover moment for the group, reaching No. 1 on the country chart and No. 5 on Billboard’s all-genre Hot 100. The group is also known for such hits as 1982’s “Bobbie Sue." Lennox Mclendon - staff, ASSOCIATED PRESS Shelley Duvall poses for photographers at the 30th Cannes Film Festival in France, May 27, 1977. Duvall, whose wide-eyed, winsome presence was a mainstay in the films of Robert Altman and who co-starred in Stanley Kubrick's “The Shining,” died July 11. She was 75. Jean-Jacques Levy - staff, ASSOCIATED PRESS Dr. Ruth Westheimer holds a copy of her book "Sex for Dummies" at the International Frankfurt Book Fair 'Frankfurter Buchmesse' in Frankfurt, Germany, Thursday, Oct. 11, 2007. Westheimer, the sex therapist who became a pop icon, media star and best-selling author through her frank talk about once-taboo bedroom topics, died on July 12, 2024. She was 96. Bernd Kammerer - stringer, ASSOCIATED PRESS Richard Simmons sits for a portrait in Los Angeles, June 23, 1982. Simmons, a fitness guru who urged the overweight to exercise and eat better, died July 13 at the age of 76. Simmons was a court jester of physical fitness who built a mini-empire in his trademark tank tops and short shorts by urging the overweight to exercise and eat better. Simmons was a former 268-pound teen who shared his hard-won weight loss tips as the host of the Emmy-winning daytime “Richard Simmons Show" and the “Sweatin' to the Oldies” line of exercise videos, which became a cultural phenomenon. Richard Drew - staff, ASSOCIATED PRESS Former NFL receiver Jacoby Jones died July 14 at age 40. Jones' 108-yard kickoff return in 2013 remains the longest touchdown in Super Bowl history. The Houston Texans were Jones’ team for the first five seasons of his career. They announced his death on Sunday. In a statement released by the NFL Players Association, his family said he died at his home in New Orleans. A cause of death was not given. Jones played from 2007-15 for the Texans, Baltimore Ravens, San Diego Chargers and Pittsburgh Steelers. He made several huge plays for the Ravens during their most recent Super Bowl title season, including that kick return. AP File Photo The "Beverly Hills, 90210" star whose life and career were roiled by tabloid stories, Shannen Doherty died July 13 at 53. Doherty's publicist said the actor died Saturday following years with breast cancer. Catapulted to fame as Brenda in “Beverly Hills, 90210,” she worked in big-screen films including "Mallrats" and "Jay and Silent Bob Strike Back" and in TV movies including "A Burning Passion: The Margaret Mitchell Story," in which she played the "Gone with the Wind" author. Doherty co-starred with Holly Marie Combs and Alyssa Milano in the series “Charmed” from 1998-2001; appeared in the “90210” sequel series seven years later and competed on “Dancing with the Stars” in 2010. Peter Kramer, Associated Press Actor James Sikking poses for a photograph at the Los Angeles gala celebrating the 20th anniversary of the National Organization for Women, Dec. 1, 1986. Sikking, who starred as a hardened police lieutenant on “Hill Street Blues” and as the titular character's kindhearted dad on “Doogie Howser, M.D.,” died July 13 of complications from dementia, his publicist Cynthia Snyder said in a statement. He was 90. Avery - staff, ASSOCIATED PRESS Pat Williams chats with media before the 2004 NBA draft in Orlando, Fla. Williams, a co-founder of the Orlando Magic and someone who spent more than a half-century working within the NBA, died July 17 from complications related to viral pneumonia. The team announced the death Wednesday. Williams was 84. He started his NBA career as business manager of the Philadelphia 76ers in 1968, then had stints as general manager of the Chicago Bulls, the Atlanta Hawks and the 76ers — helping that franchise win a title in 1983. Williams was later involved in starting the process of bringing an NBA team to Orlando. The league’s board of governors granted an expansion franchise in 1987, and the team began play in 1989. AP File Photo Lou Dobbs speaks Feb. 24, 2017, at the Conservative Political Action Conference in Oxon Hill, Md. Dobbs, the conservative political pundit and veteran cable TV host who was a founding anchor for CNN and later was a nightly presence on Fox Business Network for more than a decade, died July 18. He was 78. His death was announced in a post on his official X account, which called him a “fighter till the very end – fighting for what mattered to him the most, God, his family and the country.” He hosted “Lou Dobbs Tonight” on Fox from 2011 to 2021, following two separate stints at CNN. No cause of death was given. Alex Brandon, Associated Press Bob Newhart, center, poses with members of the cast and crew of the "Bob Newhart Show," from top left, Marcia Wallace, Bill Daily, Jack Riley, and, Suzanne Pleshette, foreground left, and Dick Martin at TV Land's 35th anniversary tribute to "The Bob Newhart Show" on Sept. 5, 2007, in Beverly Hills, Calif. Newhart has died at age 94. Jerry Digney, Newhart’s publicist, says the actor died July 18 in Los Angeles after a series of short illnesses. The accountant-turned-comedian gained fame with a smash album and became one of the most popular TV stars of his time. Newhart was a Chicago psychologist in “The Bob Newhart Show” in the 1970s and a Vermont innkeeper on “Newhart” in the 1980s. Both shows featured a low-key Newhart surrounded by eccentric characters. The second had a twist ending in its final show — the whole series was revealed to have been a dream by the psychologist he played in the other show. Mark J. Terrill - staff, ASSOCIATED PRESS Cheng Pei-pei, a Chinese-born martial arts film actor who starred in Ang Lee’s “Crouching Tiger, Hidden Dragon,” died July 17 at age 78. Her family says Cheng, who had been diagnosed with a rare illness with symptoms similar to Parkinson’s disease, passed away Wednesday at home surrounded by her loved ones. The Shanghai-born film star became a household name in Hong Kong, once dubbed the Hollywood of the Far East, for her performances in martial arts movies in the 1960s. She played Jade Fox, who uses poisoned needles, in “Crouching Tiger, Hidden Dragon,” which was released in 2000, grossed $128 million in North America and won four Oscars. Chris Pizzello - invision linkable, Chris Pizzello/Invision/AP Abdul “Duke” Fakir holds his life time achievement award backstage at the 51st Annual Grammy Awards on Feb. 8, 2009, in Los Angeles. The last surviving original member of the Four Tops died July 22. Abdul “Duke” Fakir was 88. He was a charter member of the Motown group along with lead singer Levi Stubbs, Renaldo “Obie" Benson and Lawrence Payton. Between 1964 and 1967, the Tops had 11 top 20 hits and two No. 1′s: “I Can’t Help Myself (Sugar Pie Honey Bunch)” and the operatic classic “Reach Out I’ll Be There.” Other songs, often stories of romantic pain and longing, included “Baby I Need Your Loving,” “Standing in the Shadows of Love,” “Bernadette” and “Just Ask the Lonely.” Matt Sayles, Associated Press Sculptress Elizabeth Catlett, left, then-Washington D.C. Mayor Sharon Pratt Dixon, center, and then-curator, division of community life, Smithsonian institution Bernice Johnson Reagon chat during the reception at the Candace awards on June 25, 1991 in New York. Reagon, a musician and scholar who used her rich, powerful contralto voice in the service of the American Civil Rights Movement and human rights struggles around the world, died on July 16, 2024, according to her daughter's social media post. She was 81. Chrystyna Czajkowsky - staff, ASSOCIATED PRESS John Mayall, the British blues musician whose influential band the Bluesbreakers was a training ground for Eric Clapton, Mick Fleetwood and many other superstars, died July 22. He was 90. He is credited with helping develop the English take on urban, Chicago-style rhythm and blues that played an important role in the blues revival of the late 1960s. A statement on Mayall's official Instagram page says he died Monday at his home in California. Though Mayall never approached the fame of some of his illustrious alumni, he was still performing in his late 80s, pounding out his version of Chicago blues. Sandro Campardo - foreign subscriber, ASSOCIATED PRESS Erica Ash, an actor and comedian skilled in sketch comedy who starred in the parody series “Mad TV” and “Real Husbands of Hollywood,” has died. She was 46. Her publicist and a statement by her mother, Diann, says Ash died July 28 in Los Angeles of cancer. Ash impersonated Michelle Obama and Condoleeza Rice on “Mad TV,” a Fox sketch series, and was a key performer on the Rosie O’Donnell-created series “The Big Gay Sketch Show.” Her other credits included “Scary Movie V,” “Uncle Drew” and the LeBron James-produced basketball dramedy “Survivor’s Remorse.” On the BET series “Real Husbands of Hollywood,” Ash played the ex-wife of Kevin Hart’s character. Richard Shotwell - invision linkable, Richard Shotwell/Invision/AP Jack Russell, the lead singer of the bluesy '80s metal band Great White whose hits included “Once Bitten Twice Shy” and “Rock Me” and was fronting his band the night 100 people died in a 2003 nightclub fire in Rhode Island, died Wednesday, Aug. 7, 2024. He was 63. AP Photo/Jill Connelly, file Juan “Chi Chi” Rodriguez, a Hall of Fame golfer whose antics on the greens and inspiring life story made him among the sport’s most popular players during a long professional career, died Thursday, Aug. 8, 2024. AP Photo/Steven Senne, File Susan Wojcicki, the former YouTube chief executive officer and longtime Google executive, died Friday, Aug. 9, 2024, after suffering with non small cell lung cancer for the past two years. She was 56. AP Photo/Markus Schreiber Frank Selvy, an All-America guard at Furman who scored an NCAA Division I-record 100 points in a game and later played nine NBA seasons, died Tuesday, Aug. 13, 2024. He was 91. AP Photo/Mary Ann Chastain, File Wallace “Wally” Amos, the creator of the cookie empire that took his name and made it famous and who went on to become a children’s literacy advocate, died Tuesday, Aug. 13, 2024, from complications with dementia. He was 88. AP Photo/Lucy Pemoni, File Gena Rowlands, hailed as one of the greatest actors to ever practice the craft and a guiding light in independent cinema as a star in groundbreaking movies by her director husband, John Cassavetes, and who later charmed audiences in her son's tear-jerker “The Notebook,” died Wednesday, Aug. 14, 2024. She was 94. Chris Pizzello/Invision/AP, File Peter Marshall, the actor and singer turned game show host who played straight man to the stars for 16 years on “The Hollywood Squares,” died. Thursday, Aug. 15, 2024 He was 98. Richard Shotwell/Invision/AP, File Alain Delon, the internationally acclaimed French actor who embodied both the bad guy and the policeman and made hearts throb around the world, died Sunday, Aug. 18, 2024. He was 88. Arthur Mola/Invision/AP, File Phil Donahue, whose pioneering daytime talk show launched an indelible television genre that brought success to Oprah Winfrey, Montel Williams, Ellen DeGeneres and many others, died Sunday, Aug. 18, 2024, after a long illness. He was 88. AP Photo/Mark Lennihan, File Al Attles, a Hall of Famer who coached the 1975 NBA champion Warriors and spent more than six decades with the organization as a player, general manager and most recently team ambassador, died Tuesday, Aug. 20, 2024. He was 87. AP Photo/Ben Margot, File John Amos, who starred as the family patriarch on the hit 1970s sitcom “Good Times” and earned an Emmy nomination for his role in the seminal 1977 miniseries “Roots,” died Wednesday, Aug. 21, 2024. He was 84. Amy Sussman/Invision/AP, File James Darren, a teen idol who helped ignite the 1960s surfing craze as a charismatic beach boy paired off with Sandra Dee in the hit film “Gidget,” died Monday, Sept. 2, 2024. He was 88. AP Photo, File James Earl Jones, who overcame racial prejudice and a severe stutter to become a celebrated icon of stage and screen has died. He was 93. His agent, Barry McPherson, confirmed Jones died Sept. 9 at home. Jones was a pioneering actor who eventually lent his deep, commanding voice to CNN, “The Lion King” and Darth Vader. Working deep into his 80s, he won two Emmys, a Golden Globe, two Tony Awards, a Grammy, the National Medal of Arts, the Kennedy Center Honors and was given an honorary Oscar and a special Tony for lifetime achievement. In 2022, a Broadway theater was renamed in his honor. Michael Zorn - invision linkable, Michael Zorn/Invision/AP Frankie Beverly, who with his band Maze inspired generations of fans with his smooth, soulful voice and lasting anthems including “Before I Let Go,” has died. He was 77. His family said in a post on the band’s website and social media accounts that Beverly died Sept. 10. In the post, which asked for privacy, the family said “he lived his life with a pure soul, as one would say, and for us, no one did it better.” The post did not say his cause of death or where he died. Beverly, whose songs include “Joy and Pain,” “Love is the Key,” and “Southern Girl,” finished his farewell “I Wanna Thank You Tour” in his hometown of Philadelphia in July. Patrick Semansky - freelancer, ASSOCIATED PRESS Joe Schmidt, the Hall of Fame linebacker who helped the Detroit Lions win NFL championships in 1953 and 1957 and later coached the team, has died. He was 92. The Lions said family informed the team Schmidt died Sept. 11. A cause of death was not provided. One of pro football’s first great middle linebackers, Schmidt played his entire NFL career with the Lions from 1953-65. An eight-time All-Pro, he was enshrined into the Pro Football Hall of Fame in 1973 and the college football version in 2000. Born in Pittsburgh, Schmidt played college football in his hometown at Pitt. Jose Juarez, AP File Chad McQueen, an actor known for his performances in the “Karate Kid” movies and the son of the late actor and racer Steve McQueen, died Sep. 11. His lawyer confirmed his death at age 63. McQueen's family shared a statement on social media saying he lived a life “filled with love and dedication.” McQueen was a professional race car driver, like his father, and competed in the famed 24 Hours of Le Mans and the 24 Hours of Daytona races. He is survived by his wife Jeanie and three children, Chase, Madison and Steven, who is an actor best known for “The Vampire Diaries.” Lionel Cironneau - stringer, ASSOCIATED PRESS Tito Jackson, one of the brothers who made up the beloved pop group the Jackson 5, died at age 70 on Sept. 15. Jackson was the third of nine children, including global superstars Michael and Janet. The Jackson 5 included brothers Jackie, Tito, Jermaine, Marlon and Michael. They signed with Berry Gordy’s Motown empire in the 1960s. The group was inducted into the Rock & Roll Hall of Fame in 1997 and produced several No. 1 hits in the 1970s, including “ABC,” “I Want You Back” and “I’ll Be There.” Mark Von Holden, Associated Press John David “JD” Souther has died. He was a prolific songwriter and musician whose collaborations with the Eagles and Linda Ronstadt helped shape the country-rock sound that took root in Southern California in the 1970s. Souther joined in on some of the Eagles’ biggest hits, such as “Best of My Love,” “New Kid in Town,” and “Heartache Tonight." The Songwriters Hall of Fame inductee also collaborated with James Taylor, Bob Seger, Bonnie Raitt and many more. His biggest hit as a solo artist was “You’re Only Lonely.” He was about to tour with Karla Bonoff. Souther died Sept. 17 at his home in New Mexico, at 78. In this photo, JD Souther and Alison Krauss attend the Songwriters Hall of Fame 44th annual induction and awards gala on Thursday, June 13, 2013 in New York. Charles Sykes - invision linkable, Charles Sykes/Invision/AP Sen. Dan Evans stands with his three sons, from left, Mark, Bruce and Dan Jr., after he won the election for Washington's senate seat in Seattle, Nov. 8, 1983. Evans, a former Washington state governor and a U.S. Senator, died Sept. 20. The popular Republican was 98. He served as governor from 1965 to 1977, and he was the keynote speaker at the 1968 National Republican Convention. In 1983, Evans was appointed to served out the term of Democratic Sen. Henry “Scoop” Jackson after he died in office. Evans opted not to stand for election in 1988, citing the “tediousness" of the Senate. He later served as a regent at the University of Washington, where the Daniel J. Evans School of Public Policy and Governance bears his name. Barry Sweet - staff, ASSOCIATED PRESS Eugene “Mercury” Morris, who starred for the unbeaten 1972 Miami Dolphins as part of a star-studded backfield and helped the team win two Super Bowl titles, died Sept. 21. He was 77. The team on Sunday confirmed the death of Morris, a three-time Pro Bowl selection. In a statement, his family said his “talent and passion left an indelible mark on the sport.” Morris was the starting halfback and one of three go-to runners that Dolphins coach Don Shula utilized in Miami’s back-to-back title seasons of 1972 and 1973, alongside Pro Football Hall of Famer Larry Csonka and Jim Kiick. Morris led the Dolphins in rushing touchdowns in both of those seasons. Charles Rex Arbogast, AP File John Ashton, the veteran character actor who memorably played the gruff but lovable police detective John Taggart in the “Beverly Hills Cop” films, died Thursday, Sept. 26, 2024. He was 76. Richard Shotwell/Invision/AP, file Maggie Smith, who won an Oscar for 1969 film “The Prime of Miss Jean Brodie” and won new fans in the 21st century as the dowager Countess of Grantham in “Downton Abbey” and Professor Minerva McGonagall in the Harry Potter films, died Sept. 27 at 89. Smith's publicist announced the news Friday. She was frequently rated the preeminent British female performer of a generation that included Vanessa Redgrave and Judi Dench. “Jean Brodie” brought her the Academy Award for best actress in 1969. Smith added a supporting actress Oscar for “California Suite” in 1978. Reed Saxon, Associated Press Kris Kristofferson, a Rhodes scholar with a deft writing style and rough charisma who became a country music superstar and an A-list Hollywood actor, died Saturday, Sept. 28, 2024. He was 88. Owen Sweeney/Invision/AP, File Drake Hogestyn, the “Days of Our Lives” star who appeared on the show for 38 years, died Saturday, Sept. 28, 2024. He was 70. AP Photo/Lionel Cironneau, File Ron Ely, the tall, musclebound actor who played the title character in the 1960s NBC series “Tarzan,” died Sunday, Sept. 29, 2024, at age 86. AP Photo/Reed Saxon, File Dikembe Mutombo, a Basketball Hall of Famer who was one of the best defensive players in NBA history and a longtime global ambassador for the game, died Monday, Sept. 30, 2024, from brain cancer, the league announced. He was 58. AP Photo/David Zalubowski, File Frank Fritz, left, part of a two-man team who drove around the U.S. looking for antiques and collectibles to buy and resell on the reality show “American Pickers,” died Monday, Sept. 30, 2024. He was 60. He's shown here with co-host Mike Wolfe at the A+E Networks 2015 Upfront in New York on April 30, 2015. Andy Kropa/Invision/AP, File Pete Rose, baseball’s career hits leader and fallen idol who undermined his historic achievements and Hall of Fame dreams by gambling on the game he loved and once embodied, died Monday, Sept. 30, 2024. He was 83. AP Photo/Matt Rourke, File Cissy Houston, the mother of Whitney Houston and a two-time Grammy winner who performed alongside superstar musicians like Elvis Presley and Aretha Franklin, died Monday, Oct. 7, 2024, in her New Jersey home. She was 91. Charles Sykes/Invision/AP, File Ethel Kennedy, the wife of Sen. Robert F. Kennedy, who raised their 11 children after he was assassinated and remained dedicated to social causes and the family’s legacy for decades thereafter, died on Thursday, Oct. 10, 2024, her family said. She was 96. AP Photo/Henry Burroughs, File Former One Direction singer Liam Payne, 31, whose chart-topping British boy band generated a global following of swooning fans, was found dead Wednesday, Oct. 16, 2024, after falling from a hotel balcony in Buenos Aires, local officials said. He was 31. Rich Fury/Invision/AP, File Mitzi Gaynor, among the last survivors of the so-called golden age of the Hollywood musical, died of natural causes in Los Angeles on Thursday, Oct. 17, 2024. She was 93. Richard Shotwell/Invision/AP, File Fernando Valenzuela, the Mexican-born phenom for the Los Angeles Dodgers who inspired “Fernandomania” while winning the NL Cy Young Award and Rookie of the Year in 1981, died Tuesday, Oct. 22, 2024. He was 63. AP Photo/Abbie Parr, File Jack Jones, a Grammy-winning crooner known for “The Love Boat” television show theme song, died, Wednesday, Oct. 23, 2024. He was 86. AP Photo/Reed Saxon, File Phil Lesh, a founding member of the Grateful Dead, died Friday, Oct. 25, 2024, at age 84. AP Photo/Morry Gash, File Teri Garr, the quirky comedy actor who rose from background dancer in Elvis Presley movies to co-star of such favorites as "Young Frankenstein" and "Tootsie," died Tuesday, Oct 29, 2024. She was 79. AP Photo/Mark Terrill, File Quincy Jones, the multitalented music titan whose vast legacy ranged from producing Michael Jackson’s historic “Thriller” album to writing prize-winning film and television scores and collaborating with Frank Sinatra, Ray Charles and hundreds of other recording artists, died Sunday, Nov 3, 2024. He was 91 Photo by Chris Pizzello/Invision/AP, File Bobby Allison, founder of racing’s “Alabama Gang” and a NASCAR Hall of Famer, died Saturday, Nov. 9, 2024. He was 86. AP Photo/File Song Jae-lim, a South Korean actor known for his roles in K-dramas “Moon Embracing the Sun” and “Queen Woo,” was found dead at his home in capital Seoul, Tuesday, Nov. 12, 2024. He was 39. Jo Soo-jung/Newsis via AP British actor Timothy West, who played the classic Shakespeare roles of King Lear and Macbeth and who in recent years along with his wife, Prunella Scales, enchanted millions of people with their boating exploits on Britain's waterways, died Tuesday, Nov 12, 2024. He was 90. Gareth Fuller/PA via AP Bela Karolyi, the charismatic if polarizing gymnastics coach who turned young women into champions and the United States into an international power in the sport, died Friday, Nov. 15, 2024. He was 82. AP Photo/Susan Ragan, File Arthur Frommer, whose "Europe on 5 Dollars a Day" guidebooks revolutionized leisure travel by convincing average Americans to take budget vacations abroad, died Monday, Nov. 18, 2024. He was 95. AP Photo/Seth Wenig, File) Former Chicago Bulls forward Bob Love, a three-time All-Star who spent 11 years in the NBA, died Monday, Nov. 18, 2024. He was 81. AP Photo/Fred Jewell, File Chuck Woolery, the affable, smooth-talking game show host of “Wheel of Fortune,” “Love Connection” and “Scrabble” who later became a right-wing podcaster, skewering liberals and accusing the government of lying about COVID-19, died Saturday, Nov. 23, 2024. He was 83. Ronda Churchill/Las Vegas Review-Journal via AP, File Barbara Taylor Bradford, a British journalist who became a publishing sensation in her 40s with the saga "A Woman of Substance" and wrote more than a dozen other novels that sold tens of millions of copies, died Sunday, Nov. 24, 2024. She was 91. Caroll Taveras/Bradford Enterprises via AP Hall of Famer Rickey Henderson, the brash speedster who shattered stolen base records and redefined baseball's leadoff position, died Friday, Dec. 20, 2024. He was 65. AP Photo/Jeff Chiu, File Greg Gumbel, left, watches as then-Connecticut head coach Jim Calhoun talks to Butler head coach Brad Stevens, right, prior to taping a television interview April 3, 2011, for that year's men's NCAA Final Four college basketball championship game in Houston. Gumbel's family announced Dec. 27 that the longtime CBS sportscaster died from cancer at the age of 78. Eric Gay, Associated PressCompanies tighten security after a health care CEO’s killing leads to a surge of threats

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DrBalcony App Redefines Balcony Inspections with Unparalleled EfficiencyANDOVER, Mass., Dec. 04, 2024 (GLOBE NEWSWIRE) -- MKS Instruments, Inc. (NASDAQ: MKSI), a global provider of enabling technologies that transform our world, was recognized today as one of America's Most Responsible Companies for 2025 , presented by Newsweek and Statista, Inc. "We are honored to be recognized for the second consecutive year as one of our nation's most responsible companies by Newsweek and Statista,” said John T.C. Lee, President and Chief Executive Officer of MKS. "We are committed to providing our customers with world-leading innovative technology to help them succeed in a manner that also protects our planet and the communities in which we work and live.” The America's Most Responsible Companies ranking analyzes companies through a holistic view of corporate responsibility. An overall score is calculated for each company based on over 30 key performance indicators for the top 2,000 publicly traded U.S. companies by revenue and a public survey of 26,000 U.S. residents evaluating each company's corporate social responsibility reputation. About MKS Instruments MKS Instruments enables technologies that transform our world. We deliver foundational technology solutions to leading edge semiconductor manufacturing, electronics and packaging, and specialty industrial applications. We apply our broad science and engineering capabilities to create instruments, subsystems, systems, process control solutions and specialty chemicals technology that improve process performance, optimize productivity and enable unique innovations for many of the world's leading technology and industrial companies. Our solutions are critical to addressing the challenges of miniaturization and complexity in advanced device manufacturing by enabling increased power, speed, feature enhancement, and optimized connectivity. Our solutions are also critical to addressing ever-increasing performance requirements across a wide array of specialty industrial applications. Additional information can be found at www.mks.com . Contacts: Bill Casey Senior Director, Marketing Communications Telephone: +1 (630) 995-6384 Email: [email protected] Kelly Kerry, Partner Kekst CNC Email: [email protected]

This year was busy for trusts and estates practitioners. With 2025 marking the final year of the Tax Cuts and Jobs Act (TCJA), many of its implications for federal corporate and individual income tax, gift, estate and generation-skipping transfer (GST) tax and fiduciary income tax are set to sunset on January 1, 2026. At that time, the prior transfer tax exemption amounts (indexed for inflation, using the chained consumer price index (CPI) figure) will be restored. This, alongside cooling inflation levels, has caused many individuals and families to review their existing estate plans and desire to take advantage of the higher exemption amounts. Accordingly, estate planners, appraisers, accountants and tax preparers alike worked in concert to effectuate significant gifts of cash, marketable securities and interests in entities. The Corporate Transparency Act (CTA) also went into effect on January 1, resulting in a massive amount of reporting obligations for newly formed entities. With the year-end reporting deadline for entities created prior to January 1, 2024, drawing ever closer, clients and their advisors have performed countless analyses of both simple and complicated structures to ensure the reports are filed on time. Most recently, we had a significant presidential election. In 2025 the Republicans will have control of the White House, Congress and a sympathetic Supreme Court, so it is possible that not only will some (or many) of the provisions of the TCJA get extended, but significant other tax reforms may be passed. While the permanency of the TCJA's provisions remains uncertain, the current environment provides a great deal of opportunity for new planning. Given the continuing uncertainty, we are encouraging clients, above all, to build flexibility into their estate plans and to use this window of opportunity, where appropriate, to engage in planning to take advantage of the increased estate, gift and GST tax exemptions. In prior editions of our Year-End Estate Planning Advisory, we included detailed discussions of the TCJA and its important estate planning components. If you wish to review a more thorough analysis of the TCJA and other recent legislation like the Inflation Reduction Act, please see our most here and here . The following are some key income and transfer tax exemptions and rate changes under the TCJA, including inflation-adjusted amounts for 2024 and 2025. Inflation-Adjusted Tax Figures Federal Estate, GST and Gift Tax Rates The federal estate, gift and GST applicable exclusion amounts are as summarized below. In simple terms, these dollar figures represent the amount of wealth that each individual can transfer during their lifetime and/or at death (in the aggregate) before incurring any federal transfer taxes (which currently are assessed at a maximum rate of 40 percent): The federal estate tax exemption that applies to non-resident aliens was not increased under the TCJA. Under current law, the exemption for non-resident aliens remains at $60,000 (absent the application of an estate tax treaty). Annual Gift Tax Exclusions Each year, individuals are entitled to make gifts to donees using the "Annual Exclusion Amount" without incurring gift tax or using any of their applicable exclusion amount against estate and gift taxes. The Annual Exclusion Amount, per donee, is as follows: Thus, in 2024, a married couple together can gift $36,000 to each donee without gift tax consequences. ( Consider doing so before the end of the year if you have not done so yet! ) If one spouse makes a $36,000 gift, the other spouse can agree to split the gift by consenting to gift splitting on a timely filed gift tax return. For those with noncitizen spouses, please note that the limitation on tax-free annual gifts made to noncitizen spouses will increase from $185,000 in 2024 to $190,000 in 2025. Those with citizen spouses may make unlimited gifts to their citizen spouse without incurring a gift tax or using lifetime exemption amounts. In order to qualify for the annual exclusion, gifts must be of a present interest. To the extent gifts are being made to a trust, care must be taken to ensure that the appropriate powers are included in such trust in order to qualify such gifts as present interests. Accordingly, before making any gifts, you should contact your Katten Private Wealth attorney to determine if the gifts you are contemplating qualify for the annual exclusion and if such gifts would necessitate the filing of a gift tax return. Federal Income Tax Rates There are presently seven individual income tax brackets, with a maximum rate of 37 percent. The 37 percent tax rate will affect single taxpayers whose income exceeds $609,350 in 2024 ($626,350 in 2025) and married taxpayers filing jointly whose income exceeds $731,200 in 2024 ($751,600 in 2025). Estates and trusts will reach the maximum rate with taxable income of more than $15,200 in 2024 ($15,650 in 2025). Corporate Transparency Act The CTA went into effect January 1, 2024, and requires a "Reporting Company" (described below) to disclose specific information regarding itself, its "Beneficial Owners" (described below) and its "Company Applicants" to the US Treasury Department's Financial Crimes Enforcement Network (FinCEN). The underlying purpose of the CTA is to curb illicit activity by non-transparent entities with respect to which the government does not know who is running or profiting from the entity's operations. Failing to comply with the CTA is not an advisable option because willful noncompliance may result in material criminal or civil penalties. Additional background information on the CTA and its reporting requirements can be found in our November 8, 2023 CTA Advisory and 2023 Year-End Estate Planning Advisory . In general, a "Reporting Company" means a domestic or foreign corporation, limited liability company, or other similar entity that registers with a US State or Tribal Office and is not otherwise exempt from the CTA's reporting requirements. Based upon the foregoing registration requirement, common law trusts do not meet the definition of a Reporting Company. There are currently 23 limited exceptions. Nevertheless, the scope of the CTA is quite extensive. A Reporting Company is required promptly to submit to FinCEN reports regarding (i) the Reporting Company, (ii) its Beneficial Owners (i.e., individuals that have substantial control over a Reporting Company and/or individuals that directly or indirectly own or control at least 25 percent in the aggregate of the total ownership interests (which is broadly construed) of a Reporting Company), and (iii) its Company Applicants (i.e., individuals who file the required registration and individuals who are primarily responsible for such filing). A comprehensive overview of the CTA detailing Reporting Companies, Beneficial Owners, Company Applicants and Beneficial Ownership Information is available here . There are limited, specific exemptions from the definition of a Reporting Company. A full list of those 23 exemptions is contained in the link referenced immediately above. Notably, Family Offices are not specifically exempted from the definition of a Reporting Company. However, the following exemptions from the definition of a Reporting Company may be pertinent in the Family Office/Private Wealth arena: Large Operating Company. Taxable entities that (a) employ more than 20 employees on a full-time basis in the United States, (b) filed in the previous year federal income tax returns in the United States demonstrating more than $5 million in gross receipts or sales in the aggregate, and (c) have an operating presence at a physical office within the United States. Banks. A registered bank as defined in Section 3 of the Federal Deposit Insurance Act, Section 2(a) of the Investment Company Act of 1940 or Section 202(a) of the Investment Advisers Act of 1940 (e.g., certain private trust companies). Investment Advisor. Registered investment advisors under the Investment Adviser Act of 1940 (e.g., a multifamily office). Tax-Empty Entity. Organizations described in Section 501(c) of the Internal Revenue Code of 1986 (e.g., a private foundation). Subsidiary. Wholly owned, directly or indirectly, subsidiaries of exempt entities (other than money services business, pooled investment vehicles or entities assisting a tax-exempt entity). Note that this exemption is specifically tailored to subsidiaries of exempt entities, not parent companies, holding companies or other affiliates of exempt entities. Inactive Entities. Entities formed before January 1, 2020, that (a) are not engaged in an active business, (b) are not owned by a foreign person, (c) have not experienced a change in ownership in the preceding 12-month period, (d) have not sent or received funds in an amount greater than $1,000 in the preceding 12-month period, and (e) do not otherwise hold any assets. While common law trusts are not independently considered Reporting Companies, these types of trusts can be Beneficial Owners of Reporting Companies – either under the substantial control test or the ownership test described above. For those trusts that qualify as a Beneficial Owner of a Reporting Company, the analysis regarding reportable individuals "looks through" to the following specific individuals: A beneficiary, if such beneficiary (a) is the sole permissible recipient of income and principal, or (b) has the right to demand distributions or withdraw substantially all trust assets. A trust's grantor, if such grantor has the right to revoke the trust or otherwise withdraw the assets of the trust. Trustees or other individual(s) with the authority to control or dispose of trust assets. Despite numerous comments requesting clarification, the CTA's final regulations do not provide guidance with respect to what specific individuals fall into the category of "other individuals who can dispose of trust assets" (e.g., Trust Protectors, Business Advisors, Distribution Committees or Investment Advisors). Thus, a key takeaway with respect to identifying which individuals are reportable when a trust is a Beneficial Owners of a Reporting Company is that the specific terms of the trust need to be closely examined and analyzed. Back in March 2024, Judge Liles C. Burke of the US District Court of the Northern District of Alabama issued an opinion finding that the CTA was unconstitutional. While those headlines were attractive, the ruling was limited to the specific plaintiffs in the case and was promptly appealed. Subsequent constitutional challenges in other jurisdictions have thus far not been successful. Therefore, unless and until a higher court finds that the CTA is unconstitutional, nearly all Reporting Companies remain subject to the CTA and should continue to file their Beneficial Ownership Information Reports (BOIRs). CTA reporting is already well underway. As flagged in our recent September 17, 2024 CTA Advisory , entities formed or registered to do business under the law of a US State or Indian tribe prior to January 1, 2024, must submit their initial BOIRs to FinCEN by January 1, 2025. Entities formed or registered in 2024 must submit their initial BOIRs to FinCEN within 90 calendar days of formation or registration, and entities formed or registered on or after January 1, 2025, must submit their initial BOIRs to FinCEN within 30 calendar days of formation or registration. As a reminder, each Reporting Company shall report the following information on its initial BOIR: (a) full legal name, (b) any trade name or d/b/a, (c) its principal place of business, (d) the State, Tribal, or foreign jurisdiction of its formation and (e) a unique ID number (e.g., an EIN). Moreover, each BOIR shall contain the following information about the Reporting Company's Beneficial Owners and, for Reporting Companies formed or registered to do business on or after January 1, 2024, their Company Applicants: (v) full legal name of such individual, (w) date of birth of such individual, (x) the current residential address of such individual, (y) a unique ID number for such individual (e.g., an unexpired passport number or driver's license), and (z) an image of the document from which such unique ID number was obtained. Any changes to the information set forth on a BOIR must be promptly reported (within 30 calendar days of such change) to FinCEN on an updated BOIR. CTA analysis, including determining the Beneficial Owners of a Reporting Company and whether any exemptions apply, is a fact-specific inquiry that involves a review of the CTA and its regulations, the corporate structure and the applicable governing documents. This case-by-case determination of Beneficial Owners becomes increasingly more complex when Reporting Companies are owned directly or directly by trusts. Thus, depending on the complexity of the corporate structure, including the terms of the applicable governing documents and any relevant trust agreements, CTA review and compliance may require substantial attention. Katten attorneys are available to advise and assist you with respect to CTA analysis and compliance. Important Planning Considerations for 2024 and 2025 The "big ticket" item of the TCJA is the significant increase to the lifetime gift, estate and GST tax exemptions. Under the TCJA, the exemptions were increased from $5 million (adjusted for inflation) to $10 million (adjusted for inflation). In 2024, these amounts are $13.61 million and in 2025, are $13.99 million. Absent any changes in the law , the increased exemptions under the TCJA are set to "sunset" (expire) as of January 1, 2026, back to $5 million. With inflation adjustments, it is anticipated that, after sunset, the exemptions will be in the range of $7 million in 2026, meaning individuals who do not use any of the exemptions prior to the sunset will lose nearly $7 million in their lifetime gift exemption and married coupled will lose nearly $14 million in lifetime gift exemption. What follows are several planning ideas to consider prior to the sunset. Year-End Checklist for 2024 First, before going into greater detail on available strategies, here is a short checklist of easy-to-implement estate planning strategies that can be utilized prior to the end of 2024: Make year-end annual exclusion gifts of $18,000 ($36,000 for married couples). Make year-end IRA contributions. Create 529 Plan accounts before year-end for children and grandchildren, and consider front-loading the accounts with five years' worth of annual exclusion gifts, taking into account any gifts made during the year to children and grandchildren. Pay tuition and non-reimbursable medical expenses directly to the school or medical provider. Consider making charitable gifts (including charitable Individual Retirement Account (IRA) rollovers) before year-end to use the deduction on your 2024 income tax return. Review Formula Bequests Many estate plans utilize "formula clauses" that divide assets upon the death of the first spouse between a "credit shelter trust," which utilizes the client's remaining federal estate tax exemption amount, and a "marital trust," which qualifies for the federal estate tax marital deduction and postpones the payment of federal estate taxes on the assets held in the marital trust until the death of the surviving spouse. While the surviving spouse is the only permissible beneficiary of the marital trust, the credit shelter trust may have a different class of beneficiaries, such as children from a prior marriage. With the TCJA's increase in the exemption amounts, an existing formula clause could potentially fund the credit shelter trust with up to the full federal exemption amount of $13.61 million in 2024 and $13.99 million in 2025. This formula could potentially result in a smaller bequest to the marital trust for the benefit of the surviving spouse than was intended or even no bequest for the surviving spouse at all. There are many other examples of plans that leave the exemption amount and the balance of the assets to different beneficiaries. Depending on the class of beneficiaries of the credit shelter trust, if the taxpayer lives in a state where the federal and state exemption amounts are decoupled, the taxpayer's estate may inadvertently find itself subject to estate tax at the state level. Taxpayers should review any existing formula clauses in their current estate plans to ensure they are still appropriate, given the increase in the federal exemption amounts and the implications of the potential sunset of these exemption amounts. In addition, taxpayers should consider alternative drafting strategies, such as disclaimers, to maintain flexibility in their plans. Income Tax Basis Planning Taxpayers should consider the potential tradeoffs of utilizing the increased exemption amounts during their lifetimes to gift assets to others, as opposed to retaining appreciated assets until their death so that those assets receive a stepped-up income tax basis. Taxpayers may want to consider retaining low-basis assets, which would then be included in their taxable estates and receive a step-up in income tax basis, while prioritizing high-income tax basis assets for potential lifetime gift transactions. In addition, if a trust beneficiary has unused federal estate tax exemption, consideration should be given to strategies that would lead to low-income tax basis assets currently held in trust, and otherwise not includible in a beneficiary's taxable estate, being included in the beneficiary's taxable estate, such as: granting the beneficiary a general power of appointment over the trust assets; utilizing the trust's distribution provisions to distribute assets directly to the beneficiary, so that the assets may obtain a step-up in basis upon the death of the beneficiary to whom it was distributed; or converting a beneficiary's limited power of appointment into a general power of appointment by a technique commonly known as "tripping the Delaware tax trap." Consequently, the assets included in the beneficiary's estate would receive a step-up in income tax basis at the beneficiary's death and would take advantage of the beneficiary's unused federal estate tax exemption amount. Whether these techniques should be implemented depends on a careful analysis of the basis of the assets held in trust, the beneficiary's assets and applicable exclusion amounts, which should be discussed with advisors. 529 Plan Changes The TCJA expanded the benefits of 529 Plans for federal income tax purposes. Historically, withdrawals from 529 Plans have been free from federal income tax if the funds were used toward qualified higher education expenses. Under the TCJA, qualified withdrawals of up to $10,000 can now also be made from 529 Plans for tuition in K-12 schools. As a result, the owner of the 529 Plan can withdraw up to $10,000 per beneficiary each year to use towards K-12 education. The earnings on these withdrawals will be exempt from federal income tax under the TCJA. However, because each state has its own specific laws addressing 529 Plan withdrawals and not all states provide that withdrawals for K-12 tuition will be exempt from state income taxes, taxpayers should consult with their advisors to confirm the rules in their respective states. A concern with 529 plans is that leftover funds no longer needed for educational purposes may be trapped in the account unless a penalty is paid when the account is withdrawn for a non-qualified purpose. SECURE 2.0 (discussed further below) permits a beneficiary of 529 accounts to roll over up to $35,000 over their lifetime from any 529 account into a Roth IRA. Planning to Utilize Increased Federal Exemptions Given that the increased federal exemption amounts are currently set to sunset at the end of 2025, it may be prudent to make use of these increased amounts before they disappear (with the caveat that the law may, of course, change prior to 2026). We note that a change in the law can occasionally occur with little advanced notice and that 2025 will be a very busy time for estate planners and, perhaps more importantly, appraisers. Accordingly, for individuals who plan to use their exemption prior to the end of 2025, clients are encouraged to complete that planning in 2024 to avoid the 2025 rush (plus, the sooner an individual acts, the more appreciation on and income from the transferred assets can accumulate outside of the taxable estate). Gifting Techniques to Take Advantage of the Increased Applicable Exclusion Amount Taxpayers may want to consider making gifts to utilize the increased federal exclusion amount. It is less expensive to make lifetime gifts than to make gifts at death because tax is not imposed on dollars used to pay gift tax, but estate tax is imposed on the dollars used to pay estate tax. In addition, taxpayers may benefit by removing any income from and appreciation on the gift from their estate. However, taxpayers should seek advice if they have used all their applicable exclusion amount and would pay federal gift tax on any gifts. Making gifts that result in significant gift tax payments may not always be advisable in the current environment. A countervailing consideration of lifetime gifting is that the gifted assets will not get a step-up in basis upon death (as would assets held at death) and will thus generate capital gains tax if they are subsequently sold for an amount higher than their basis. The Internal Revenue Service (IRS) released Revenue Rule 2023-02, which reiterated this previously well-established trade-off. Accordingly, the decision of whether and how to embark on a lifetime gifting strategy depends on several factors, including the basis of the transferor's various assets, their projected income and appreciation, the total amount of the transferor's assets and the transferor's remaining applicable exclusion amount. For individuals with assets far exceeding their applicable exclusion amounts, lifetime gifting of high-basis assets generally may be recommended. However, individuals with total assets close to or below their applicable exclusion amounts should exercise caution before making gifts of low-basis assets. Instead, those individuals should consider holding their assets until death to achieve a step-up in basis upon death while minimizing estate taxes. Of course, maintaining a comfortable standard of living is a factor that also must be considered. We are available to discuss this analysis with you in more detail. If undertaking a gifting strategy, gifts to utilize the increased exemption may be made to existing or newly created trusts. For instance, a taxpayer could create a trust for the benefit of the taxpayer's spouse (a spousal lifetime access trust (SLAT)) and gift assets to the SLAT utilizing the taxpayer's increased federal exemption amounts. The gifted assets held in the SLAT should not be includible in the taxpayer's or spouse's respective taxable estates, and distributions could be made to the spouse from the SLAT to provide the spouse with access to the gifted funds, if needed, in the future. Of course, marital stability and the health of the other spouse need to be considered. Additionally, gifts could be made by a taxpayer to dynasty trusts (to which GST exemption is allocated), which would allow the trust property to benefit future generations without the imposition of estate or GST tax. There are several important considerations to remember when using a SLAT or SLATs. Both the taxpayer and the taxpayer's spouse can create SLATs for each other, but the SLATs cannot be "reciprocal." That is to say, the two SLATs cannot have the same trust terms with the only difference being the identity of the beneficiary. Under the reciprocal trust doctrine, gifts made to irrevocable trusts that are deemed reciprocal are treated as being included in each grantor's taxable estate, which leads to the opposite of the desired result. There are several easy ways to ensure that SLATs are not reciprocal, namely: having a different class of beneficiaries (i.e., spouse versus spouse and descendants); including powers of appointment with different classes of potential appointees; different termination date of each SLAT; and distribution standard (best interests versus support). Another important consideration when utilizing multiple SLATs is the timing of the gifts. This is particularly important if the taxpayer and the taxpayer's spouse have unequal assets. In a situation where one spouse has a significantly larger portion of a married couple's assets, SLATs can still be used, first with one spouse gifting a portion of assets to the other spouse, followed by the receiving spouse gifting the same assets to a SLAT for the benefit of the first spouse. Importantly, and in particular, when considering the impending sunset of the exemption amounts, this is not a strategy that can be implemented in the span of a few days, weeks, or perhaps, even in a month or the same calendar year. Although there is no clear answer, the 2021 Smaldino case provides some guidance. See Smaldino v. Commissioner , T.C. Memo 2021-127. In Smaldino , the taxpayer engaged in a series of transactions, as follows: The taxpayer transferred a 41 percent interest in an LLC to his spouse. One day later , the spouse transferred the same 41 percent LLC interest to a Dynasty Trust for the benefit of the taxpayer's descendants. That same day, the taxpayer transferred an additional 8 percent in the LLC to the Dynasty Trust. The end result was the taxpayer owned a 51 percent interest in the LLC, and the Dynasty Trust owned a 49 percent interest in the LLC. The Tax Court held that the taxpayer made a gift of a 49 percent interest in the LLC to the Dynasty Trust because the taxpayer's spouse was never admitted as a member of the LLC, never exercised the rights of a member and no evidence was presented that the spouse ever received any benefit or burden of being a member. As a result of the finding, gift tax was assessed against the taxpayer. Although Smaldino had some particularly egregious facts for the taxpayer, the importance of the timing of such transactions cannot be understated. Notably, Smaldino did not specify a timeline that would have deemed the taxpayer's spouse's gift of the 41 percent LLC interest valid. In an ideal situation, a sequence of transactions that requires the taxpayer to make a gift to the taxpayer's spouse prior to the taxpayer's spouse gifting those same assets would be completed over separate tax years (i.e., a gift to the taxpayer's spouse in 2024 tax year, a spouse's gift to irrevocable trust in 2025 tax year). With limited time remaining until the sunset, now is the time to consider such a gifting strategy. In addition to using a SLAT, taxpayers may make gifts to irrevocable dynasty trusts (to which GST exemption is allocated) for the benefit of the taxpayer's children and/or more remote descendants to allow trust property to benefit future generations. If the strategy is properly implemented, no estate or GST tax will be incurred. Other Techniques to Take Advantage of the Increased Applicable Exclusion Amount In addition to making gifts to utilize the increased exemption, below is a summary of several other broadly applicable recommendations: Sales to Grantor Trusts. In addition to making gifts to irrevocable trusts, taxpayers should consider sales to grantor trusts (or a combination gift/sale). A sale would be in exchange for a down payment (say 10 percent) and a promissory note for the balance, and any interest payments owed back to the grantor may not be subject to income tax, nor should the sale trigger capital gains tax (since the taxpayer is also the taxpayer of the grantor trust for income tax purposes, so it is essentially a sale to oneself). The increased federal exemption may provide a cushion against any asset valuation risk attendant with such sales. Taxpayers who enter into such sale transactions should consider taking advantage of the adequate disclosure rules to start running the three-year statute of limitations. Interest rates on promissory notes are presently at high rates but generally are still advantageous to engage in this type of transaction. Of course, the asset being sold, if not publicly traded, should be appraised by a qualified appraiser. Loan Forgiveness/Refinancing. If taxpayers are holding promissory notes from prior estate planning transactions, from loans to family members or otherwise, they should consider using some or all the increased federal exemption amounts to forgive these notes. Consideration could be given to refinancing existing notes, but given the higher interest rates, that may not be advantageous at present. Allocation of GST Exemption to GST Non-Exempt Trusts. If a taxpayer's existing estate plan utilizes trusts that are subject to GST tax (GST non-exempt trusts), consideration should be given to allocating some or all of the taxpayer's increased GST exemption amount to such trusts. Balancing Spouses' Estates. For married taxpayers, if the value of the assets owned by one spouse is greater than the increased federal exemption amounts and greater than the value of the assets owned by the other spouse, consideration should be given to transferring assets to the less propertied spouse. Such a transfer would provide the less propertied spouse with more assets to take advantage of the increased federal exemption amounts, especially the increased GST exemption, which is not portable to the surviving spouse upon the first spouse's death. Taxpayers should be mindful, however, that transfers to non-US citizen spouses are not eligible for the unlimited marital deduction for federal gift tax purposes, and such transfers should stay within the annual exclusion for such gifts ($185,000 in 2024; $190,000 in 2025) to avoid federal gift tax. Additionally, creditor protection should be considered before transferring assets from the joint name or from one spouse's name to the other spouse's name. Note that the annual exclusion for gifts (to donees other than a spouse) is $18,000 in 2024 and $19,000 in 2025. Life Insurance. Taxpayers may wish to review or reevaluate their life insurance coverage and needs with their insurance advisors. Review and Revise Your Estate Plan to Ensure It Remains Appropriate As noted above, any provisions in wills and trust agreements that distribute assets according to tax formulas and/or applicable exclusion amounts should be reviewed to ensure that the provisions continue accurately to reflect the testator's or grantor's wishes when taking into account the higher applicable exclusion amounts. Consideration should also be given to including alternate funding formulas in wills or trust agreements that would apply if the federal estate tax exemption amounts do sunset in 2026. Additionally, in light of the increased exemption amounts, taxpayers should also consider whether certain prior planning is now unnecessary and should be unwound, such as certain qualified personal residence trusts, family limited partnerships (FLPs) and split-dollar arrangements. Allocation of GST-applicable exclusion amounts should be reviewed to ensure that it is utilized most effectively if one wishes to plan for grandchildren or more remote descendants. In addition, due to the increased GST exemption amounts available under the TCJA, allocation of some or all of one's increased GST exemption amounts to previously established irrevocable trusts that are not fully GST exempt may be advisable. Taxpayers should continue to be cautious in relying on portability in estate planning, as portability may not be the most beneficial strategy based on your personal situation. In addition, a deceased spouse's unused exclusion (DSUE) may not be available upon remarriage of the surviving spouse. Furthermore, since the DSUE amount is frozen upon the first spouse's death, no appreciation is allocated to the DSUE amount between the first spouse's death and the surviving spouse's subsequent death, which would limit the amount of transfer-tax-free assets that could pass to beneficiaries. However, when a credit shelter trust is used in lieu of portability, the appreciation of the assets funding the credit shelter trust will inure to the beneficiaries' benefits. However, portability may be a viable option for some couples with estates below the combined exemption amounts. Portability can be used to take advantage of the first spouse to die's estate tax exemption amount, as well as obtain a stepped-up basis at each spouse's death. Portability can also be used in conjunction with a trust for the surviving spouse (a QTIP trust) to incorporate flexibility for post-mortem planning options. Factors such as the asset protection benefits of utilizing a trust, the possibility of appreciation of assets after the death of the first spouse, and the effective use of both spouses' GST exemption and state estate tax should be discussed with advisors in determining whether relying on a portability election may be advisable. For taxpayers looking to make a portability election, effective July 8, 2022, Rev. Proc. 2022-32 provides certain taxpayers with a more simplified method to make the portability election, allowing them to be able to elect the portability of a DSUE up to five years after the decedent's date of death. Unmarried couples should particularly continue to review and revise their estate planning documents and beneficiary designations. Since the advent of same-sex marriage, it is now clear that domestic partners, even if registered as such, do not qualify for the federal (and in many cases state) tax and other benefits and default presumptions that are accorded to married couples. Finally, in view of the potential sunset of many pertinent provisions of the TCJA, estate plans should provide as much flexibility as possible. As noted above, formula bequests should be reviewed to ensure they are appropriate under current law, and consideration should be given to granting limited powers of appointment to trust beneficiaries to provide flexibility for post-mortem tax planning. A trust protector (or trust protector committee) may also be appointed to give a third party the ability to modify or amend a trust document based on changes in the tax laws or unforeseen future circumstances or to grant certain powers to trust beneficiaries that may have tax advantages under a new tax regime (such as the granting of a general power of appointment to trust beneficiaries in order to obtain a stepped-up basis in trust assets at the beneficiary's death). Mitigate Trust Income Tax and Avoid the Medicare Surtax With Trust Income Tax Planning Non-grantor trusts should consider making income distributions to beneficiaries. Trust beneficiaries may be taxed at a lower tax rate, especially due to the compressed income tax brackets applicable to non-grantor trusts. Additionally, a complex, non-grantor trust with an undistributed annual income of more than $12,500 (adjusted for inflation) will be subject to the 3.8 percent Medicare surtax. However, some or all of the Medicare surtax may be avoided by distributing such income directly to beneficiaries who are below the individual net investment income threshold amount for the Medicare surtax ($200,000 for single taxpayers, $250,000 for married couples filing jointly and $125,000 for married individuals filing separately). To determine whether trusts should distribute or retain their income, beneficiaries' circumstances and tax calculations should be carefully evaluated. Transfer Techniques Many techniques that have been utilized in prior years continue to be advantageous planning techniques under the TCJA. Due to the potential sunsetting of many applicable provisions of the TCJA, consideration should be given to planning that minimizes the risk of paying current gift taxes but still allows taking advantage of the increased exemptions amounts to shifting assets and appreciation from the taxable estate. Additionally, consideration should be given to selling hard-to-value assets to grantor trusts, due to the increased exemption available to "shelter" any valuation adjustment of these assets upon audit. Lifetime gifting and sales transactions remain very important in providing asset protection benefits for trust beneficiaries, shifting income to beneficiaries in lower tax brackets, and providing funds for children or others whose inheritance may be delayed by the longer life expectancy of one's ancestors. Grantor Retained Annuity Trusts (GRATs) GRATs remain one of our most valuable planning tools, though given recent higher interest rates, their practicality has decreased. Under current law, GRATs may be structured without making a taxable gift. Therefore, even if one has used all his or her applicable exclusion amount, GRATs may be used without incurring any gift tax. Because GRATs may be created without a gift upon funding, they are an increasingly attractive technique for clients who want to continue planning to pass assets to their descendants without payment of gift tax in the uncertain tax environment. A GRAT provides the grantor with a fixed annual amount (the annuity) from the trust for a term of years (which may be as short as two years). The annuity the grantor retains may be equal to 100 percent of the amount the grantor used to fund the GRAT, plus the IRS-assumed rate of return applicable to GRATs. For transfers made in November 2024, this is 4.4 percent. For transfers made in December 2024, the applicable rate will be 5 percent. As long as the GRAT assets outperform the applicable rate, at the end of the annuity term the grantor will be able to achieve a transfer tax-free gift of the spread between the actual growth of the assets and the IRS assumed rate of return. Although the grantor will retain the full value of the GRAT assets, if the grantor survives the annuity term, the value of the GRAT assets in excess of the grantor's retained annuity amount will then pass to whomever the grantor has named, either outright or in further trust, with no gift or estate tax. Qualified Personal Residence Trust (QPRT) A similar type of transaction is a transfer of the taxpayer's residence to an irrevocable QPRT. A QPRT allows the taxpayer to enjoy the use of the property for a predetermined term. A gift to a QPRT will result in a taxable gift, but the value of the gift is the present value of the grantor's remainder interest in the property, which is dependent in part on the term of the QPRT. The value of the gift also accounts for any mortgage or other debt on the property. When the QPRT terminates, the residence is distributed to the remainder beneficiaries (or to a continuing trust for their benefit), and all the appreciation in the property is outside of the grantor's taxable estate. If the grantor still desires to reside in the property, the grantor can lease the property from the remainder beneficiaries (or from a continuing trust for their benefit) for fair market value, which provides an additional income stream to the trust, and the rent payments are taken out of the grantor's taxable estate without incurring any gift tax. Sales to Intentionally Defective Grantor Trusts (IDGTs) Sales to IDGTs have become an increasingly popular planning strategy due to the increased exemption amounts under the TCJA. In utilizing a sale to an IDGT, a taxpayer would transfer assets likely to appreciate to the IDGT in exchange for a down payment (say 10 percent) and a promissory note from the trust for the balance. From an income tax perspective, no taxable gain would be recognized on the sale of the property to the IDGT because it is a grantor trust, which makes this essentially a sale to oneself. For the same reason, the interest payments on the note would not be taxable to the seller or deductible by the trust. If the value of the assets grows at a greater pace than the prevailing applicable federal rate (AFR) (For sales in November 2024 the rate is 4 percent for a short-term note. In December 2024 the rate is 4.3 percent for a short-term note.), as with a GRAT, the appreciation beyond the federal rate will pass free of gift and estate tax. The increased federal exemption amounts may provide a cushion against any asset valuation risk attendant to such sales. Additionally, the increased exemption amounts permit the sale of a substantially larger amount of assets to grantor trusts. Typically, grantor trusts should be funded with at least 10 percent of the value of the assets that will be sold to the trust. With the higher exemption amounts, those who have not used any of their exemptions could contribute up to $13.61 million (or $27.22 million if splitting assets with a spouse) to a grantor trust in 2024. This would permit the sale of up to $136.1 million (or $272.2 million) of assets to the trust in exchange for a promissory note with interest at the appropriate AFR. Consider a Swap or Buy Back of Appreciated Low-Basis Assets From Grantor Trusts If a grantor trust has been funded with low-basis assets, the grantor should consider swapping or buying back those low-basis assets in exchange for high-basis assets or cash. If the grantor sold or gave (through a GRAT or other grantor trust) an asset with a low basis, when that asset is sold, the gain will trigger capital gains tax. However, if the grantor swaps or purchases the asset back from the grantor trust for fair market value, no gain or loss is recognized. The trust would then hold cash or other assets equal to the value of the asset that was repurchased. Alternatively, many grantor trust instruments give the grantor the power to substitute the trust's assets with other assets, which would allow the low-basis assets to be removed from the trust in exchange for assets of equal value that have a higher basis. Then, on the grantor's death, the purchased or reacquired asset will be included in the grantor's taxable estate and will receive a step-up on a basis equal to fair market value, eliminating the income tax cost to the beneficiaries. Those whose estates may not be subject to estate taxes due to the current high exemption amounts may utilize swaps or buy-backs to "undo" prior planning strategies that are no longer needed in today's environment. Particular care should be taken when considering swapping assets that are hard to value. In that circumstance, an appraisal from a qualified appraiser should be obtained to support the valuation of the swapped assets. This not only helps limit fiduciary liability claims but also protects against an argument that the swap was not done for assets of equal value, which could potentially result in a gift being made by the grantor to the trust. Consider the Use of Life Insurance Life insurance presents significant opportunities to defer and/or avoid income taxes, as well as provide assets to pay estate tax or replace assets used to pay estate tax. Generally speaking, appreciation and/or income earned on a life insurance policy accumulates free of income taxes until the policy owner makes a withdrawal or surrenders or sells the policy. Thus, properly structured life insurance may be used as an effective tax-deferred retirement planning vehicle. Proceeds distributed upon the death of the insured are generally completely free of income taxes. Taxpayers should consider paying off any outstanding loans against existing policies in order to maximize the proceeds available tax-free at death, although potential gift tax consequences must be examined. Note that the decision to pay off such loans requires a comparison of the alternative investments that may be available with the assets that would be used to repay the loans and the interest rate on the loans. Use Intra-Family Loans and Consider Refinancing Existing Intra-Family Loans While these techniques work better when interest rates are low, because the exemption amounts are so high, many techniques involving the use of intra-family loans should be considered, including: The purchase of life insurance on the life of one family member by an irrevocable life insurance trust, with premium payments funded by loans from other family members. The creation of trusts by older generation members for the benefit of younger family members, to which the older generation members provide a small seed gift and then loan more substantial funds. The spread between the investment return earned by the trust and the interest owed on the note will create a transfer tax-free gift. Forgiving loans previously made to family members. The amount that is forgiven in excess of the annual gift tax exclusion amount will be a gift and thus will use a portion of one's applicable gift tax and/or GST tax exclusion amount. This may be a beneficial strategy considering the increased exemption amounts. Installment Sale to Third-Party Settled GST Tax-Exempt Trust Unique planning opportunities and transfer tax benefits may be available if a relative or friend of the taxpayer has an interest in creating and funding a trust for the benefit of the taxpayer and/or the taxpayer's family. For example, a third-party grantor (e.g., a relative or friend of the taxpayer) could contribute cash to a trust for the benefit of the taxpayer, allocate GST tax exemption to that gift, and then that trust could purchase assets from the taxpayer in exchange for such cash and a secured promissory note in the remaining principal amount of assets purchased. While this sale could result in payment of capital gains tax to the taxpayer (ideally at an earlier, lower value), this planning could present the following potential benefits: there should be no transfer tax concerns for the third-party grantor if the grantor's other assets, even when added to the value of the foregoing gift, would not be sufficient to cause the estate tax to apply at the grantor's death (this depends on what the estate tax exemption amount is at the grantor's subsequent death); the assets could receive a step-up in basis as of the date of the initial sale; the taxpayer could be a beneficiary, hold a limited power of appointment over, and control who serves as trustee, of the trust; the appreciation in the value of the asset being sold from the date of the initial sale above the interest rate on the promissory note (e.g., 3.7 percent is the mid-term AFR for a sale completed in November 2024 and 4.18 percent is the mid-term AFR for a sale completed in December 2024) would accrue transfer-tax-free for the benefit of the taxpayer and/or the taxpayer's family; and the trust could be structured in such a way as to provide protection from the taxpayer's creditors and remove the trust assets from the taxpayer's and his or her family members' taxable estates. To achieve the foregoing benefits, it is important that only the third-party grantor makes gratuitous transfers to the trust and that the third-party grantor is not reimbursed for such transfers. Disclaimer Planning If applicable, taxpayers may consider disclaiming assets they stand to inherit from a predeceased spouse or other relative. This keeps the disclaimed assets out of the taxpayer's estate, and if structured properly, the disclaimer is not treated as a gift. This could be a useful tool for taxpayers looking to take advantage of the GST exemption, as the GST exemption is not portable and does not receive the same double exemption as the gift/estate tax exemptions receive. Additionally, this may be useful in a jurisdiction like New York, where the state-level estate tax exemption is lower than the federal estate exemption. Accordingly, by a surviving spouse disclaiming assets that are going to be received from the deceased spouse and using some or all of the deceased spouse's available estate tax exemption, it is possible that the resulting net worth of the surviving spouse is below the state-level estate tax exemption. Consider Charitable Planning A planning tool that is very effective in a high-interest rate environment is a Charitable Remainder Annuity Trust (CRAT), which combines philanthropy with tax planning. A CRAT is an irrevocable trust that pays an annual payment to an individual (typically the grantor) during the term of the trust, with the remainder passing to one or more named charities. The grantor may receive an income tax deduction for the value of the interest passing to charity. Because the value of the grantor's retained interest is lower when interest rates are high, the value of the interest passing to charity (and therefore the income tax deduction) is higher. Alternatively, a strategy that works better in a low interest rate environment is a Charitable Lead Annuity Trust (CLAT). A CLAT is an irrevocable trust that pays one or more named charities a specified annuity payment for a fixed term. At the end of the charitable term, any remaining assets in the CLAT pass to the remainder, noncharitable beneficiaries. As with a GRAT, to the extent the assets outperform the IRS assumed rate of return, those assets can pass transfer-tax-free to the chosen beneficiaries. A CLAT may become an attractive option if interest rates fall. Be mindful of the ability to make IRA charitable rollover gifts, which allows an individual who is age 70 1/2 or over to make a charitable rollover of up to $100,000 (adjusted for inflation, pursuant to SECURE 2.0, discussed next) to a public charity without having to treat the distribution as taxable income. Other types of charitable organizations, such as supporting organizations, donor-advised funds or private foundations, are not eligible to receive the charitable rollover. Therefore, if a taxpayer needs to take a required minimum distribution, he or she may arrange for the distribution of up to $100,000 (adjusted for inflation) to be directly contributed to a favorite public charity and receive the income tax benefits of these rules. Due to new limitations on itemized deductions (i.e., the cap on the state and local tax deduction), some taxpayers may no longer itemize deductions on their personal income tax returns. Without itemized deductions, these taxpayers could not receive the income tax benefit of a charitable deduction for charitable contributions. Retirement Planning The Setting Every Community Up for Retirement Enhancement Act of 2019 (the SECURE Act), was originally signed into law on December 20, 2019. Intended to assist and encourage Americans in saving and investing for retirement, the SECURE Act incentivizes retirement planning by providing Americans with more choices for retirement saving, as well as increasing access to tax-advantaged savings plans. On December 29, 2022, the SECURE Act 2.0 (SECURE 2.0) was signed into law as part of the Consolidated Appropriations Act, 23, with SECURE 2.0 intended to build upon the original SECURE Act. SECURE 2.0 brings major changes to the administration of IRAs, both during the lifetime of the IRA account holder and after the account holder's death. The IRS released the final regulations for SECURE 2.0 on July 19, 2024. SECURE 2.0 and the final regulations create a new structure for IRA required minimum distribution (RMDs) for all IRA owners and the IRA owner's designated beneficiaries. With SECURE 2.0, the required beginning date (RBD) for the start of RMDs is delayed as follows to April 1 of the year following the year in which the individual turns: (i) age 72 for an individual who was born in calendar year 1950 or earlier ( note that the RBD is still age 70 1/2 for those who attained age 70 1/2 prior to December 31, 2019 ); (ii) age 73 for an individual who was born on or after January 1, 1951 and before December 31, 1959; and (iii) age 75 for individuals who were born in calendar year 1960 or later. Further, 2.0's finalized regulation clarified that the RBD for individuals born in calendar year 1959 will be age 73 (as individuals born in 1959 previously had two RBDs, age 73 and age 75). The finalized SECURE 2.0 regulations formalized a new "10-year rule" pertaining to RMDs by beneficiaries of inherited IRAs. Designated beneficiaries of inherited IRAs are classified as either "Eligible Beneficiaries" or "Non-Eligible Beneficiaries." Individual Eligible Beneficiaries include surviving spouses, disabled and chronically ill persons, minor children of the original IRA owner or persons not more than 10 years younger than the original owner. Individual Non-Eligible Beneficiaries encompass a broader class of beneficiaries and include most non-spouse beneficiaries. The 10-year rule requires that an individual Non-Eligible Designated Beneficiary who inherits an IRA from an account owner who died prior to the original account owner's RBD fully distribute the inherited IRA on or before the end of the 10th anniversary of the original account owner's death. During the 10-year period, Non-Eligible Beneficiaries are required to take, at a minimum, stretch-style distributions each year until year-end of the calendar year that includes such 10th anniversary, at which year-end the IRA must be fully distributed. With respect to a Non-Eligible Beneficiary who inherits from an IRA owner who has already begun taking distributions, the remaining interest in the IRA must be distributed at least as rapidly (the ALAR Rule) as the original account holder was taking distributions as of his or her date of death. This means that an inherited IRA can be subject to both the 10-year rule and the ALAR Rule. Eligible Designated Beneficiaries are not subject to the 10-year rule and may choose between traditional stretch distributions and the 10-year rule (although the plan administrator can restrict options). The surviving spouse of a deceased account holder will be able to elect to have the inherited account treated as their own. However, the finalized regulations do require a surviving spouse to take "hypothetical RMDs" if the 10-year rule treatment is not elected. If a surviving spouse initially elects 10-year rule treatment on the inherited IRA but subsequently elects a spousal rollover of said account, the surviving spouse will be required to take make-up payments of the hypothetical RMDs to the current date. For purposes of determining whether an Eligible Designated Beneficiary is a minor under a 10-year rule analysis, an Eligible Designated Beneficiary is a minor until age 21. Upon attaining age 21, the 10-year rule applies to the beneficiary and the beneficiary must take annual stretch-style RMDs during the next 10 years covered by the 10-year rule, just as with an individual Non-Eligible Designated Beneficiary. Another new feature of SECURE 2.0 and the finalized regulations concerns Roth IRAs. Under SECURE 2.0, if the entire IRA interest is held in a designated Roth account, a Non-Eligible Beneficiary subject to the 10-year rule will not be required to take a distribution in the first nine years after inheriting the IRA but rather can take the entire distribution in year 10. Please note, however, that a Non-Eligible Designated Beneficiary can only elect this treatment if the entire IRA interest must be held in a designated Roth IRA. SECURE 2.0 has also brought about significant changes to trust beneficiaries of IRAs. SECURE 2.0 classifies most trusts as Non-Eligible Designated Beneficiaries, subjecting most trusts to the 10-year rule and creating complications if a trust is named as a beneficiary of an IRA. However, SECURE 2.0 permits certain trusts to take stretch-style distributions, as discussed below. Whether a trust beneficiary of an inherited IRA is subject to SECURE 2.0's 10-year rule or can take traditional stretch-style distributions requires an analysis of the trust's underlying beneficiaries. If a trust is classified as a "see-through" trust, the trust's beneficiaries will be deemed to be the ultimate beneficiaries of the inherited IRA. Generally, SECURE 2.0 creates two categories of see-through trusts for RMD purposes. The first such trust is called a "conduit trust," meaning a trust in which all distributions from an IRA are required to be distributed to specific beneficiaries pursuant to the original IRA owner's estate plan. The other type of trust is known as an "accumulation trust," whereby distributions from an IRA are allowed to accumulate in trust, and all trust beneficiaries are treated as beneficiaries of the inherited IRA. As the 10-year rule applies to most trusts, an analysis of a trust's beneficiaries is required to determine whether such beneficiaries qualify as an Eligible Designated Beneficiary or a Non-Eligible Designated Beneficiary. Just like with individuals who inherit an IRA, most non-spouse beneficiaries of a trust that inherit an IRA will be subject to the 10-year rule and designated as a Non-Eligible Beneficiary. Further, trusts that divide on the original IRA holder's death will require an analysis of each subtrust. By way of example, a trust that divides into five separate subtrusts on the account holder's death will require five separate analyses as to whether each trust is an Eligible Designated Beneficiary or a Non-Eligible Designated Beneficiary. In addition, and as is the case with individuals, the ALAR Rule applies to inherited IRAs where distributions have already started. Traditional stretch-style distributions are generally available to trust beneficiaries who would otherwise qualify as Eligible Designated Beneficiaries. SECURE 2.0 permits irrevocable trusts benefitting a chronically ill or disabled individual to take traditional stretch-style distributions if such trust is an "applicable multi-beneficiary trust" (AMBT). An AMBT limits distributions to the chronically ill beneficiary during his or her lifetime (and then can subsequently make payments to other beneficiaries). SECURE 2.0 allows a qualified charity to be designated as the remainder beneficiary of an AMBT inheriting an IRA and for the qualified charity to take traditional stretch-style distributions following the death of the trust's initial beneficiary. SECURE 2.0 and the finalized regulations have also provided new rules regarding the exercise of a power of appointment (POA) for beneficiaries of see-through trusts. SECURE 2.0 permits a beneficiary to hold and exercise POA over his or her trust following the death of the original IRA account holder. SECURE 2.0 permits the powerholder/beneficiary to both exercise their POA by September 30 of the year of the original IRA owner's death or modify their POA to a restricted group of identifiable individuals. Any such exercise or modification by the powerholder/beneficiary will cause the newly named individuals to be considered beneficiaries of the IRA. In terms of required documentation for plan administrators, SECURE 2.0 requires the trustee of a trust designated as the beneficiary of an IRA to provide the plan administrator either (i) a copy of the trust instrument, or (ii) a list of all beneficiaries of the trust (describing how and when a beneficiary is entitled to a distribution). With respect to RMDs for years prior to January 1, 2025, IRS Notice 2024-35 provides that the IRS will not impose penalties for failure to take an RMD for years one through nine from an inherited IRA that is otherwise subject to the 10-year rule. Otherwise, the final SECURE 2.0 regulations confirm the prior SECURE 2.0 penalties. Starting January 1, 2025, failure to take an RMD from an inherited IRA will result in a penalty of 25 percent of the RMD amount, reduced to 10 percent if timely corrected. The SECURE 2.0 provides a few changes to catch-up contributions to certain retirement plans for individuals age 50 or older. High-income employees over age 50 (those who earn more than $145,000, indexed for inflation) must make any "catch-up" contributions into a designated Roth account in such plans. Individuals over age 50 who earn less than $145,000 can continue making any catch-up contributions directly to their regular 401(k) account. Under the SECURE Act 2.0, catch-up contribution levels are now indexed for inflation. Note that the IRS has delayed the effectiveness of these rules until January 1, 2026. SECURE 2.0 permits a beneficiary of a 529 Plan to make a tax-free rollover of any remaining funds into a Roth IRA (not to exceed the annual Roth IRA contribution limit), provided that the 529 Plan account has been open for at least 15 years and the funds used for the rollover have been in the 529 Plan for at least five years. The lifetime amount a beneficiary can rollover from their 529 Plan to a Roth IRA tax-free is $35,000, and such an amount is not indexed for inflation. Another feature of SECURE 2.0 is the ability for an account holder to withdraw up to $1,000 from their account for certain emergency expenses (generally defined as an unforeseeable or immediate financial need relating to personal or family expenses) without incurring a 10 percent early withdrawal penalty. There is also an option to repay the distribution within three years. If the withdrawn emergency amounts are not repaid during that three-year window, no additional emergency distributions will be allowed. SECURE 2.0 has slightly modified the rules governing qualified charitable distributions (QCDs). A QCD is a payment by an IRA account holder directly from the IRA to a qualified charity. Individuals aged 70 1/2 or older can contribute an amount not to exceed $100,000, now indexed for inflation and $105,000 in 2024, to a qualified charity. Select Federal Caselaw Updates United States v. Paulson , 131 AFTR 2d 2023-1743 (9th Cir. May 17, 2023) [EP116-125] Allen Paulson (the Decedent) died on July 19, 2000, survived by his third wife Madeleine Pickens (Madeleine), three sons from a prior marriage, Richard Paulson (Richard), James Paulson (James) and John Michael Paulson, and several grandchildren, including granddaughter Crystal Christensen (Crystal). Richard post-deceased his father and was survived by his wife, Vikki Paulson (Vikki). The Decedent's gross estate, valued at approximately $200 million, was mostly held in a revocable trust (the Trust). Years after the Decedent's death, following multiple disputes between the Decedent's fiduciaries and beneficiaries, audit inquiries, and failed elections to defer payment of the Decedent's federal estate taxes, roughly $10 million of federal estate taxes, plus interest and penalties, remained unpaid. The United States ultimately brought suit against certain of the Decedent's heirs in their capacities as trustees, transferees or beneficiaries (collectively, the defendants), alleging that they were personally liable for the Decedent's unpaid estate tax liabilities pursuant to Internal Revenue Code (Code) Section 6432(a)(2). While the lower court held that a beneficiary was not liable for unpaid estate taxes as a beneficiary of the Trust because they didn't receive life insurance benefits, and other beneficiaries were not liable for unpaid estate taxes because they were not in possession of the estate's property at the time of the Decedent's death, the US Court of Appeals for the Ninth Circuit (the Court) reversed the lower court's decision and held that persons who hold estate property or receive it on or after the date of death are personally liable for unpaid estate taxes on that property. In so holding, the Court was the first to interpret the provisions and legislative history of said Section 6432(a)(2) to determine its meaning. Code Section 6432(a)(2) imposes personal liability for a decedent's estate taxes on transferees and others who receive or have property from an estate. It states, in the relevant part: "If the estate tax imposed by chapter 11 is not paid when due, then the spouse, transferee, trustee (except the trustee of an employees' trust which meets the requirements of section 401(a)), surviving tenant, person in possession of the property by reason of the exercise, nonexercised, or release of a power of appointment, or beneficiary, who receives, or has on the date of the decedent's death, property included in the gross estate under sections 2034 to 2042, inclusive, to the extent of the value, at the time of decedent's death, of such property, shall be personally liable for such tax" (26 U.S.C. Section 6432(a)(2)). One question before the Court was whether the limiting phrase "on the date of the decedent's death" modifies only the preceding verb "has" or also the more remote verb "receives." The Court ruled in favor of the United States that the phrase "on the date of decedent’s death" does not limit the verb "receives," holding that Code Section 6432(a)(2) "imposes personal liability for unpaid estate taxes on the categories of persons listed in the statute who have or receive estate property, either on the date of the decedent's death or at any time thereafter, subject to the applicable statute of limitations." In so ruling, the Court followed "the rule of the last antecedent," which provides that a limiting clause should be read to modify only the noun or verb immediately before it. Contrary to the opinion of the single dissenting Circuit Judge, the Court also noted that to accept another interpretation would be contrary to the statutory text and context, even though it would be possible, under the decided interpretation, for the personal liability of an individual to exceed the value of the property received by them if such property had significantly declined in value after receipt. Overall, the Court felt there were sufficient safeguards preventing this remote possibility from materializing, especially considering the government's affirmations that the personally liable transferee is only responsible to the extent that the property actually had or was received by such an individual. After deciding that Code Section 6432(a)(2) imposes personal liability on those categories of persons listed in the statute who have or receive estate property on or after the date of the decedent's death, the Court was tasked with determining whether the categories of people listed included the defendants. The Court held that Vikki, Crystal and James were successor trustees of the Trust, and therefore liable for unpaid estate taxes in such capacity to the extent of the value of the property included in the Trust at the time of the Decedent's death. The Court also found Crystal and Madeleine liable as beneficiaries of the Trust, finding more broadly, based on contextual case law and analogous statutory usage, that the term "beneficiary" as used in Code Section 6432(a)(2) included a "trust beneficiary." The case was remanded to the district court to calculate the proportion of estate taxes owed by each personally liable individual. As a practical result of Paulson , a nominated successor trustee may wish to inquire as to the liabilities of an estate or trust before accepting their role. Additionally, executors and trustees should consider withholding distributions until all estate or trust liabilities are satisfied. On the other hand, beneficiaries who receive distributions should learn whether there are any outstanding liabilities of the estate or trust before spending their distributions. In a case where the payment of estate tax was duly deferred, the timeline for observing these precautions may be extended. Schlapfer v. Comm'r of Internal Revenue , T.C. Memo 2023-65 On May 22, 2023, the Tax Court issued a decision in Schlapfer v. Comm'r , T.C. Memo 2023-65, making its first ruling on what constitutes adequate disclosure of a gift for gift tax purposes under Treas. Reg. 301.6501(c)-1(f)(2). By ultimately applying a "substantial compliance" approach to disclosure, the Tax Court favorably found that the taxpayer met the requirements for adequate disclosure despite not adhering to a stricter standard. By way of background, Ronald Schlapfer (Taxpayer) had ties to both Switzerland and the United States. In connection with his career, in 1979, Taxpayer moved to the United States from Switzerland and obtained a non-immigrant visa, declaring his intention not to reside permanently in the United States. At the time, Taxpayer's mother, aunt, brother and uncle – his only family – remained in Switzerland. Between 1979 and applying for US citizenship on May 18, 2007, Taxpayer was married, had children, got divorced and in 1990, was remarried to his current wife (Mrs. Schlapfer) with whom Taxpayer had a son in 1992. Also, in 2002, Taxpayer started his own business, European Marketing Group, Inc. (EMG), a Panamanian corporation that managed investments, holding cash and marketable securities. At the time of EMG's formation, Taxpayer owned all 100 issued and outstanding shares of common stock of EMG. On July 7, 2006, Taxpayer applied for a LifeBridge Universal Variable Life Policy (the Policy). His stated purpose for taking out the Policy was to create and fund a policy that Taxpayer's mother, aunt and uncle (his brother died in 1994) could use to support Taxpayer's nephews. Taxpayer was the initial owner of the Policy, the mother, aunt and uncle were named as the insured, and Taxpayer and Mrs. Schlapfer were designated as primary beneficiaries. On September 22, 2006, the Policy was issued. By November 8, 2006, Taxpayer had transferred $50,000 in cash and his 100 shares of EMG to an account in order to fund the premium payments on the Policy. On January 24, 2007, the Policy was assigned to Taxpayer's mother as owner, and by May 31, 2007, the Policy had been irrevocably assigned to Taxpayer's mother, aunt and uncle as joint owners. As part of the Offshore Voluntary Disclosure Program (OVDP) meant to give US taxpayers with offshore assets an opportunity to comply with US tax reporting and payment obligations, in 2012, Taxpayer filed a Form 709, US Gift (and Generation-Skipping Transfer) Tax Return for the year 2006, along with several supporting documents. One such document was a protective filing for the gift of 100 shares of EMG, described as a controlled foreign corporation, having a value of $6,056,686. The protective claim stated that the gift was not subject to gift tax because at the time the gift was made, Taxpayer did not intend to reside permanently in the United States. Taxpayer inaccurately reported the gift as a gift of EMG shares and not a gift of the Policy because he thought the Policy was an example of an entity that the OVDP instructions required be disregarded upon filing. He also stated that the EMG shares were assigned to his mother, even though the ultimate assignment was to Taxpayer's mother, aunt and uncle as joint owners. In June 2014, the IRS responded to Taxpayer's OVDP submission with a request for additional documentation and information, to which Taxpayer timely responded in July 2014. In January 2016, the IRS opened an examination of Taxpayer's 2006 Form 709. Ultimately, after discussions and the IRS's assertion that that the gift was actually a gift of the Policy in 2007 (and not the EMG shares in 2006), the IRS issued a notice of deficiency claiming Taxpayer was liable for $4,429,949 of gift tax and $4,319,200 worth of additions to tax. Both the IRS and Taxpayer filed summary judgment motions with the Tax Court, with Taxpayer, on the other hand, asserting that the three-year limitations period applicable to the gift had run, given Taxpayer's adequate disclosure of the gift on his 2006 Form 709. Accordingly, the question before the Tax Court was whether the gift in question, as reported on Taxpayer's 2006 Form 709, satisfied the rules of adequate disclosure such that the statute of limitations had expired before the IRS claimed a deficiency. Code Section 6501(c)(9) provides that the Commissioner may assess a gift tax at any time if a gift is not shown on a return unless the gift is "disclosed in such return, or in a statement attached to the return, in a manner adequate to apprise the Secretary of the nature of such item." Prior case law provides that disclosure is considered adequate if it is "sufficiently detailed to alert the Commissioner and his agents as to the nature of the transaction so that the decision as to whether to select the return for audit may be a reasonably informed one" ( Thiessen v. Commissioner , 146 T.C. 100, 114 (2014), quoting Estate of Fry v. Commissioner , 88 T.C. 1020, 1023 (1987)). Treasury Regulation 301.6501(c)-1(f)(2) provides that transfers reported on a gift tax return will be considered adequately disclosed if the return provides the following information: (i) a description of the transferred property and consideration received therefor; (ii) the identity of and relationship between each transferee and the transferor; (iii) if transferred in trust, the trust EIN and description its terms, or, in lieu of such a description, a copy of the trust instrument; (iv) a description of the method used to determine the fair market value of the transferred property; and (v) a statement describing any position contrary to any proposed, temporary or final Treasury regulations or revenue rulings. The provisions of Code Section 6501(c)(9) and analogous Code provisions provide support that the information relating to a gift disclosed on documents other than the gift tax return (for example, the supporting documents submitted through the OVDP) is properly considered when analyzing whether the gift was adequately disclosed. Additionally, in Treasury Decision 8845, the IRS provided that its express rejection of a "substantial compliance" approach did not mean "that the absence of any particular item or items would necessarily preclude satisfaction of the regulatory requirements, depending on the nature of the item omitted and the overall adequacy of the information provided." With this as background, the Court held that the Taxpayer substantially complied with the requirements of Treas. Reg. 301.6501(c)-1(f)(2) such that the IRS was adequately apprised of the nature of the gift. With respect to requirement (i), even if Taxpayer failed to describe the gift correctly, stating the gift was of the EMG shares and not the Policy itself, he provided sufficient information regarding the underlying asset, (i.e., the EMG shares), the value of which primarily comprised the value of the Policy. Regarding Taxpayer's identification of the transferees and his relationship with them, the fact that he inaccurately stated only his mother as a transferee was held immaterial since the other transferees were also family members, and there would be no change to understanding the nature of the gift had his aunt and uncle been identified from the start. Finally, the financial reports of EMG that were provided with Taxpayer's submission to the OVDP were sufficient to allow the Court to determine the fair market value of the EMG shares. Thus, the Court held that Taxpayer met the requirements for adequate disclosure, and, accordingly, the three-year statute of limitations, including extensions, had expired prior to the IRS's issuance of the notice of deficiency. Anenberg v. Commissioner , 162 T.C. No. 9 (May 20, 2024) Alvin Anenberg (Decedent) died in 2008 and was survived by his wife, Sally Anenberg (Sally), and two sons from a prior marriage. At his death, pursuant to his estate plan, assets (including shares of Decedent's business) were distributed to a QTIP marital trust (Marital Trust) for Sally. The Marital Trust required that trust income be distributed to Sally, at least annually, and it authorized the Trustee to distribute principal to Sally for her support. Upon Sally's death, the assets of the Marital Trust were to be distributed to Decedent's sons. In October 2011, the Trustee of the Marital Trust petitioned a state court to terminate the Marital Trust and distribute all the assets outright to Sally. Sally and the remainder beneficiaries consented to the petition. The court approved, and all the assets of the Marital Trust were distributed to Sally. A few months later, Sally gifted and sold the assets (including shares of Decedent's business) to trusts for Decedent's children and grandchildren. Sally timely filed a 2012 gift tax return reporting the gifts to the trusts and reporting the sales as non-gift transactions. In December 2020, the IRS issued a Notice of Deficiency, asserting that Sally's estate owed over $9 million in gift tax as a result of the termination of the Marital Trust and the subsequent sales of the company shares under IRC Section 2519. Generally, IRC Section 2519 provides that the disposition of a qualifying income interest in a QTIP Marital Trust is treated as a transfer of all the remainder interests in the property. Sally's estate argued that neither the termination of the Marital Trust nor the subsequent sales constituted a gift because Sally received full consideration for the property she was deemed to transfer. Under IRC Section 2501(a)(1), gift tax is imposed on the transfer of property by gift – a transfer that is made without receiving full and adequate consideration. The Tax Court agreed with the estate and unanimously rejected both of the IRS's positions. The court began its analysis by reviewing the policy behind QTIP marital trusts which is to defer taxation on QTIP trust assets until the death of the surviving spouse. It found that, at the time of the termination of the Marital Trust, even if a transfer occurred for purposes of IRC Section 2519, no gift resulted when the assets were distributed to Sally because she received full ownership of the assets in return. These assets would be subject to estate tax upon Sally's death. Accordingly, imposing a current gift tax on the value of the remainder interest under IRC Section 2519 would result in double taxation. The court also found that no deemed transfer under IRC Section 2519 occurred when Sally sold the company shares following the termination of the Marital Trust. Once the Marital Trust was terminated, the qualifying income interest for life terminated and there could be no disposition of something that did not exist. Notably, the court did not address whether Decedent's sons made a gift by consenting to the termination and distribution of the Marital Trust assets to Sally. McDougall v. Commissioner , 163 T.C. No. 5 (September 17, 2024) Clotilde McDougall (the Decedent) died in 2011 and was survived by her husband, Bruce McDougall (Bruce), and their two children, Linda and Peter. At her death, pursuant to her estate plan, assets were distributed to a QTIP marital trust (Marital Trust) for Bruce. The Marital Trust required that trust income be distributed to Bruce, at least annually, and it authorized the Trustee to distribute principal to Bruce for his health, education, maintenance and support. Upon Bruce's death, the assets of the Marital Trust were to be distributed to the Decedent's children. In October 2016, Bruce and the children entered into a non-judicial settlement agreement (the Agreement) to terminate the Marital Trust and to distribute all the assets outright to Bruce. On the same day, Bruce sold the assets he received from the Marital Trust to a trust for his children (the Children's Trust) in exchange for a promissory note. Bruce, Linda and Peter each timely filed their own gift tax returns disclosing the transactions as non-gift transactions. The IRS issued a Notice of Deficiency to Bruce asserting that the termination of the Marital Trust and subsequent sale of the Marital Trust assets to the Children's Trust were subject to gift tax under IRC Section 2519. Generally, IRC Section 2519 provides that the disposition of a qualifying income interest in a QTIP marital trust is treated as a transfer of all the remainder interests in the property. In addition, the IRS issued a Notice of Deficiency to Peter and Linda asserting that the agreement resulted in gifts of their remainder interests in the Marital Trust to Bruce under IRC Section 2511. IRC Section 2511 provides that the gift tax shall apply to any gratuitous transfer whether the transfer is in trust or otherwise, whether the gift is direct or indirect, and whether the property is real or personal, tangible or intangible. With respect to Bruce, the Tax Court rejected the IRS's position. It applied its holding in Anenberg and found that Bruce did not make a gift upon the termination of the Marital Trust because he received full consideration for the property he was deemed to transfer. Accordingly, Bruce was put in the same position he would have been in had the property been distributed outright to him at Decedent's death rather than to the Marital Trust. In addition, the Tax Court rejected the IRS's argument that the subsequent sale of the Marital Trust assets for promissory notes triggered IRC Section 2519. As described in Anenberg , once the Marital Trust was terminated, the qualifying income interest for life terminated so there could be no disposition of something that did not exist. With respect to Linda and Peter, the Tax Court agreed with the IRS and found that a gift was made to Bruce under the Agreement. The court explained that before Linda and Peter entered into the Agreement, they held valuable property rights (i.e., the remainder interests in the Marital Trust). After they consented to the Agreement, Linda and Peter gave up those rights by agreeing that all the Marital Trust assets would be distributed to Bruce for which they received nothing in return. By giving up something for nothing, the Tax Court agreed that Linda and Peter engaged in gratuitous transfers subject to gift tax under IRC Sections 2501 and 2511. Connelly v. United States 144 S. Ct. 1406 (2024) In Connelly , the US Supreme Court addressed whether the value of life insurance proceeds used by a corporation to redeem a deceased shareholder's shares should be included in the decedent's estate for federal estate tax purposes. Two brothers, Michael and Thomas Connelly, owned a closely held family roofing and siding business, Crown C Supply, Inc (Crown). The brothers had a stock purchase agreement governing the disposition of company stock on the first of their deaths, giving the surviving brother the right to purchase the deceased brother's shares. If the surviving brother chose not to exercise that right, Crown was required to redeem the shares. Crown had purchased $3.5 million in life insurance on each brother to fund such a redemption. After Michael's death, Crown redeemed the shares from Michael's estate for $3 million, using the life insurance proceeds. Thomas, as the executor of Michael's estate, reported the value of Michael's shares as $3 million on the federal estate tax return. The IRS audited the return and determined that the $3 million value of the life insurance proceeds used for the redemption should be included in the valuation of Michael's shares in Crown. The IRS thus adjusted upward the total value of Crown to $6.86 million, resulting in Michael's 77.18 percent interest being valued at approximately $5.3 million. Based on this higher valuation, the IRS assessed an additional estate tax of $889,914. Michael's estate paid the additional estate tax under protest and filed for a refund. At the District Court level, relying on Blount v. Commissioner , Michael's estate argued that the life insurance proceeds used for the redemption should not be considered part of the corporation's value. In Blount , the Eleventh Circuit had allowed insurance proceeds to be excluded if they were offset by a redemption obligation. The District Court rejected this argument and granted summary judgment for the government, holding that the life insurance proceeds should be included in the valuation of the estate. The court ruled that the redemption obligation did not reduce the fair market value of Crown, as the redemption itself did not diminish the economic value of the corporation or the shares. The estate appealed to the Eighth Circuit, which upheld the District Court's ruling. The Eighth Circuit agreed that the life insurance proceeds should be included in the calculation of the corporation's fair market value for estate tax purposes. The Eighth Circuit emphasized that, under established tax law, life insurance proceeds payable to a corporation are considered an asset that increases the company's value. The court did not view the redemption obligation as a liability that would reduce this value because a fair market value redemption would leave the remaining shareholders' proportional ownership unchanged in economic terms. The Eighth Circuit's decision reaffirmed that life insurance proceeds cannot be excluded when calculating the value of an estate's shares. The US Supreme Court granted certiorari and unanimously affirmed the lower courts' rulings. The Court rejected the reasoning from Blount and held that a corporation's contractual obligation to redeem shares using life insurance proceeds is not a liability that reduces the corporation's value for federal estate tax purposes. The Court's analysis hinged on the principle that a redemption at fair market value does not affect any shareholder's economic interest and so does not diminish the corporation's value. The Court also found that including the proceeds as part of the corporation's fair market value is consistent with standard valuation principles and statutory estate tax requirements. The ruling emphasized that the key question in estate tax valuation is the value of the decedent's property at the time of death – not how the corporation's value might change post-redemption. Connelly has significant implications, particularly for closely held family businesses that use life insurance to fund stock redemptions. Connelly establishes that life insurance proceeds payable to a corporation must be included when calculating the fair market value of the corporation for federal estate tax purposes, even if those proceeds are earmarked for redeeming a decedent's shares. Connelly will also influence how family-owned businesses structure buy-sell agreements and plan for business succession. When a corporation is obligated to redeem a deceased owner's shares, the life insurance proceeds used to fund that redemption will now increase the value of the corporation, thereby increasing the taxable value of the estate. Business owners may need to reconsider using redemption agreements as part of their succession plans, as this approach now carries the risk of increasing the estate tax burden. Estate planners may need to explore alternative planning options, such as cross-purchase agreements, in which the surviving shareholders directly purchase the shares of a deceased owner using life insurance proceeds. In this structure, the life insurance proceeds are paid directly to the purchasing shareholders – rather than to the corporation – thereby avoiding the increase in the corporation's value. That said, cross-purchase agreements introduce other complexities, such as requiring each shareholder to obtain life insurance on the other owners. Connelly reinforces the importance of proper valuation techniques in estate tax planning. Executors and estate planners must carefully assess the fair market value of closely held corporations, account for all assets (including life insurance proceeds) and structure agreements to minimize estate tax liability. In sum, Connelly reaffirms the IRS's position on the inclusion of life insurance proceeds in estate valuations and underscores the need for careful estate planning to minimize tax liabilities for closely held businesses. Estate planners should evaluate existing agreements and explore strategies that align with the Court's ruling to avoid unexpected tax consequences. Loper Bright Enterprises v. Raimondo , 603 U.S. ___ (2024) In Loper Bright , the US Supreme Court fundamentally altered the landscape of administrative law by overruling Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. , a key precedent that had shaped judicial review of agency interpretations of federal statutes for four decades. " Chevron deference" required courts to defer to reasonable agency interpretations of ambiguous statutes. Under such deference, agencies enjoyed significant discretion in interpreting statutory language – arguably expanding the scope of their regulatory authority and shifting the balance of power in favor of executive agencies over the judiciary. Loper Bright stems from the National Marine Fisheries Service's (NMFS) interpretation of the Magnuson-Stevens Fishery Conservation and Management Act (MSA), from which the agency implemented a rule requiring fishing companies to pay for at-sea monitors – an "industry-funded program." A group of family-owned fishing companies challenged the rule, arguing that the MSA did not authorize the NMFS to impose these costs. Applying Chevron deference, the lower courts found the NMFS's interpretation of the MSA to be reasonable, and so upheld the agency's rule. But in a landmark decision, 1 the Supreme Court overruled Chevron after concluding that Chevron deference was incompatible with the constitutional role of the judiciary and the Administrative Procedure Act's (APA) mandate that courts decide "all relevant questions of law." Instead, the Court held that courts must exercise independent judgment in interpreting ambiguous statutes without deferring to agency interpretations. The Court closely examined the APA, which governs judicial review of agency action, noting that Section 706 of the APA mandates that "the reviewing court shall decide all relevant questions of law." The Court reasoned that giving agencies such deference effectively forced courts to relinquish their statutory duty under the APA to decide legal questions. The Court also noted that Congress passed the APA in 1946 as a direct response to limit the growing administrative state, and the APA's clear language suggested that Congress intended for courts to retain their traditional role of interpreting statutes – an intent that Chevron deference undermined. The Court's opinion emphasized constitutional concerns about Chevron , drawing heavily from foundational separation of powers precedents. Because Article III empowers the judiciary with the authority to resolve legal disputes, and because Chevron blurred this separation of powers principle by allowing executive branch agencies to interpret the law, the Court concluded that Chevron undermined the judiciary's core responsibility to interpret statutes and serve as a check on the executive branch power. Despite Chevron 's 40-year run, the Court rejected arguments that it should uphold Chevron on the basis of stare decisis . The Court described Chevron as unworkable and confusing in its application, cited several exceptions and qualifications that had been imposed on Chevron in its progeny, and noted that Chevron had become a tangled doctrine leading to inconsistent rulings – all factors undermining a decision to uphold precedent based on stare decisis . Even so, the Court acknowledged the continued relevance of Skidmore deference, under which courts may give weight to agency interpretations based on their persuasiveness. Such Skidmore deference, however, is fundamentally different from Chevron deference in that Skidmore deference does not demand judicial deference, but permits courts to consider the agency's expertise, consistency and reasoning without surrendering the court's ultimate judgment. The Court's opinion fundamentally reshapes administrative law and will have far-reaching implications not only for federal agencies and the "administrative state," but also for areas of tax law and estate planning, where agency interpretations of ambiguous statutory provisions play a critical role. The overruling of Chevron fundamentally redefines the relationship between courts and federal agencies, curtailing the agencies' authority to interpret statutory ambiguities without judicial oversight and placing the power of statutory interpretation firmly with the judiciary. The implications could be sweeping. For tax practitioners, courts will no longer defer to the IRS's interpretation of tax regulations. Instead, courts will conduct their own independent analysis, which could lead to increased challenges to key areas of tax law. This increased scrutiny may also complicate tax compliance, as taxpayers and tax practitioners would need to rely less on IRS interpretations and more on judicial precedent – which may be inconsistent across circuits. The burden on courts may also increase from the resurrection of challenges to portions of the tax code that were once thought to be settled based on deference to the IRS's interpretation of its regulations. Similarly, ambiguities in gift, estate and generation-skipping transfer tax statutes may now be subject to judicial interpretation, rather than agency determinations, and this shift could introduce uncertainty into estate planning strategies that rely on regulatory guidance. Estate planners may also need to reconsider certain tax-saving techniques that were previously upheld under deference to IRS regulations. Loper Bright marks a significant shift in administrative law, particularly affecting the balance of power between agencies and the judiciary. By overruling Chevron , the Court has reasserted the role of the judiciary in statutory interpretation, which is likely to have profound impacts across many areas of law. Agencies will now face greater challenges in defending their interpretations of ambiguous statutes, and courts will do more to determine the meaning of federal laws, leading to greater scrutiny of regulatory actions in complex and ambiguous legal regimes. Legislative Proposals President-Elect Donald Trump has not published a comprehensive tax plan as of the time of this writing, but he and Vice President-Elect J.D. Vance have made several proposals in campaign speeches, interviews and online. Though Trump has not articulated specific details, he generally supports making the tax cuts under the TCJA permanent, which includes extending the increased estate and gift tax exemption amount and maintaining a transfer tax rate of 40 percent. On individual income tax, Trump has not provided details on whether he would further lower tax rates, but he has considered replacing income taxes altogether with increased tariffs. To the extent a personal income tax remains, Trump has proposed that tips, overtime pay, income earned by Americans living abroad and Social Security benefits should be exempt from income tax. On long-term capital gains and dividends tax, Trump has not confirmed whether he supports reducing the maximum long-term capital gains tax rate from the current 20 percent to 15 percent. On corporate income tax, Trump has endorsed reducing the current 21 percent rate to 20 percent, and even as low as 15 percent for corporations making products domestically. Trump is opposed to the clean-energy tax credits enacted under the Inflation Reduction Act of 2022. On deductions, Trump has supported eliminating the $10,000 cap on deductions for state and local taxes (the so-called SALT deduction). Trump's position marks a reversal from his previous term in office, as it was he who imposed the $10,000 SALT deduction cap as part of the TCJA. On tax credits, Trump has supported J.D. Vance's suggestion of a $5,000 child tax credit. International Developments It has been back to business as usual for the IRS and Department of the Treasury in 2024. US tax authorities are not shaking up the international private client landscape, but instead are providing useful guidance for taxpayers and tax professionals by releasing long-awaited proposed regulations on the reporting of foreign trusts and foreign gifts and publishing a memorandum detailing certain abusive foreign micro-captive insurance arrangements that are likely to come under more scrutiny. The Supreme Court has taken a similar tack in providing a narrow ruling in a case that many opined could lay the foundations for a net-wealth tax in the United States. We have included a summary of these and other material developments from 2024 that will affect the international private client landscape going forward. Proposed Foreign Trust and Foreign Gift Regulations In May 2024, the IRS released proposed regulations covering the reporting of foreign gifts and interactions with foreign trusts. These long-awaited regulations provided guidance in respect of both Form 3520, Annual Return to Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts, and Form 3520-A, Annual Information Return of Foreign Trust With a U.S. Owner. In addition to the guidance normally accompanying regulations on IRS forms (e.g., filing deadlines, procedures for requesting an extension, rules for dual-resident taxpayers and married couples), the proposed regulations also set forth new ideas regarding the taxation of loans from foreign trusts, uncompensated use of trust property and their related reporting which in some cases differs from current reporting requirements. Under Section 643(i) of the Code, both (i) a loan from a foreign trust to a US person grantor or beneficiary or a US person related party to that US person grantor or beneficiary, and (ii) uncompensated use of trust property by a US person beneficiary or US person related party to that US beneficiary are treated as distributions to that US person grantor or beneficiary equal to the amount loaned or the fair market value of the uncompensated use of trust property. The proposed regulations changed the treatment of loans from a foreign trust by providing a carve-out for certain qualified obligations and changed the treatment of uncompensated use of trust property by attributing uncompensated use of trust property by a non-US person related to a US person grantor or beneficiary to such US person grantor or beneficiary. Regarding the carve-out for loans from foreign trusts, the proposed regulations provide an exception to the general rule of Section 643(i) of the Code for loans of cash in exchange for a qualified obligation. A loan of cash (not marketable securities or other property) may be in exchange for a qualified obligation if it meets the following requirements: (i) the obligation is in writing; (ii) the term does not exceed five years; (iii) payments are made in cash in US dollars; (iv) the obligation is issued at par and provide for stated interest at a fixed rate or qualified floating rate; (v) the yield to maturity is not less than 100 percent nor greater than 130 percent of the AFR based on the same compounding period (with corresponding rules for qualified floating rates); and (vi) all stated interest must be qualified stated interest. In addition to the above, for the initial year of the qualified obligation and each subsequent year in which the obligation is outstanding, the US grantor or beneficiary that received or is attributed the loan must (i) agree to extend the period for assessment in respect of the loan; (ii) report the status of the obligation including outstanding principal and interest payments; and (iii) must make all payments of principal and interest in accordance with the terms of the obligation. A reasonable grace period of no more than 30 days may be allowed for late payments. If any of the above requirements are not met, including following modifications to the qualified obligation, the outstanding principal plus any accrued but unpaid interest is treated as distributed to the US person grantor or beneficiary on the date the obligation ceases to be qualified. Regarding the expansion of uncompensated use of trust property to include use by non-US persons related to a US grantor or beneficiary, the proposed regulations intend to treat such use by a non-US person related party (excluding a non-US person beneficiary) as a distribution to the related US person grantor or beneficiary unless certain filing requirements are met. If the non-US person-related party was related to more than one US person grantor or beneficiary, the distribution would be split equally amongst all related US persons. The IRS provides an exception to this treatment for US taxpayers that meet their normal reporting requirements in respect of such use but also includes an explanatory statement detailing how the non-US person-related party would have used the trust property without regard to the US person grantor or beneficiary's relationship to the foreign trust. The proposed regulations also include a similar rule and exception for US person grantors or beneficiaries that receive a loan from a related party of a foreign trust and provide an explanatory statement showing how the loan may have been made absent their relationship with the foreign trust. In addition to the explanatory statements discussed above, deemed distribution treatment under Section 643(i) of the Code for use of trust property can be avoided if the foreign trust is paid fair market value for the use of the property within a reasonable period from the beginning of the use. The proposed regulations provide additional guidance on fair market value of the use and the terms and timing of repayment. Fair market value and reasonable period for these purposes are based on all facts and circumstances, including the type of property used and the period of use, and payments may be made on a periodic basis if consistent with arm's length dealings. The IRS helpfully also provides a safe harbor provision to the reasonable period requirement for payment made or periodic payments beginning within 60 days of the start of the use. Additionally, the IRS provides a de minimis safe harbor that mimics the so-called "Masters" or "Augusta" rule allowing for US person grantors or beneficiaries to avoid deemed distribution treatment for uncompensated use of trust property provided that such use by the group of US person grantors and beneficiaries does not in the aggregate exceed 14 days during the calendar year. The period for public comment on the proposed regulations ended in July 2024. Taxpayers and tax professionals now await the final version of these regulations which may not be identical to the proposed rules discussed above. IRS Details Abusive Foreign Micro-Captive Insurance Company Fact Pattern Also in May 2024, the IRS published Chief Counsel Advice Memorandum 202422010 detailing a fact pattern used by certain abusive foreign micro-captive insurance companies to help IRS agents in examinations. The fact pattern focuses on a foreign-regarded entity making an election under Section 953(d) of the Code, allowing foreign insurance companies to be treated as domestic corporations. Following this election, an insured domestic entity makes direct payments to the foreign captive company (or indirect payments if the foreign captive is the reinsurer) that are claimed to be deductible insurance premiums. The insured domestic entity does not deduct or withhold tax on the insurance payments made to the foreign captive. The foreign captive files a Form 1120-PC, U.S. Property and Casualty Insurance Company Income Tax Return, and reports the payments received from the insured domestic entity but excludes them from taxable income using the alternative tax for certain small insurance companies provided by Section 831(b) of the Code. Following examinations of the foreign captive and insured domestic entity, the IRS found that neither entity could establish that payments made under the above fact pattern were insurance premiums. This finding was based on the arrangement lacking "insurance risk, risk distribution, or risk shifting, or was not insurance in its commonly accepted sense." As a result of this finding, more than half of the business of the foreign micro-captive was not insurance business making the captive ineligible for the 953(d) election and unable to use the 831(b) alternative tax. With the foreign captive no longer being treated as a domestic entity, the insured domestic entity should have been withholding 30 percent of the gross amount of Fixed, Determinable, Annual or Periodical (FDAP) payments made to the foreign captive. This Memorandum should serve as a good indication that the IRS is likely paying closer attention to arrangements similar to the fact pattern above going forward. Supreme Court Upholds Mandatory Repatriation Tax In June 2024, the Supreme Court delivered its opinion in Moore v. United States . The Moores challenged the constitutionality of the Mandatory Repatriation Tax (MRT), also called the "Transition Tax" under Section 965 of the Code. The MRT subjected US persons owning 10 percent or more of a controlled foreign corporation (a CFC) to US federal income tax on their pro rata share of the post-1986 untaxed foreign earnings of the CFC. By way of background, in 2006, the Moores invested in a friend's CFC in India and received a 13 percent ownership stake. The business was profitable but did not distribute income to the Moores or other American shareholders. When the MRT was introduced, the Moores were forced to include their pro rata share of the untaxed foreign earnings of the Indian CFC in their income and ultimately paid roughly $15,000 in taxes. The Moores's stated that income (and therefore income taxation) requires realization, and they argued the MRT did not tax income that they had realized. Answering the question of whether realization was a prerequisite to income taxation was thought by many to be a potential stepping stone to the introduction of a net-wealth tax. In light of this, many commentators believed that the Supreme Court would issue a narrow ruling limiting their judgment only to the matter at hand. As expected, the Supreme Court issued a very narrow ruling upholding the MRT. The opinion draws many parallels between the MRT and both "Subpart F" or passive income of a CFC and pass-through taxation of partnerships and S-corporations and notes that both forms of taxation have been long accepted and constitutional in the United States. The Court also limited its ruling to tax on shareholders of an entity in respect of undistributed income realized by that entity, which has been attributed to the shareholders, when the entity has not been subject to US federal income tax on such income. The Supreme Court noted that realization was not a question they needed to answer, as the income had been realized by the CFC. Consequently, they did not rule on this point. As many had hoped, this ruling was relatively uneventful and did not set the precedent for the introduction of a net-wealth tax in the United States. Tax Treaty Updates We reported last year on the Senate's approval of the dual tax treaty between the United States and Chile. At that time, President Biden and the Chilean government both needed to give approval and have since done so. The US-Chile Dual Tax Treaty has since gone into effect applying from February 1, 2024, for withholding taxes and from January 1, 2024, for all other taxes. As part of the treaty coming into force, Chile has been added to the list of treaty partner countries in Notice 2024-11 used to determine whether a corporation is a qualified foreign corporation whose individual shareholders may benefit from reduced tax rates on dividends received. Hungary and Russia have both been removed from the list following the suspension of each country's dual tax treaty with the United States last year. The suspension of the US-Hungary Dual Tax Treaty officially went into effect for amounts paid or credited after January 1, 2024. Ultimately, we saw fewer legal changes in the international private client arena in 2024 than in 2023. Although some of the guidance issued this year may have been surprising to taxpayers and tax professionals, they can appreciate the importance of additional insight into the US government's position on issues relevant to private clients everywhere. Hopefully, the US international developments in 2024 are not an outlier, and we will see more useful guidance affecting the global private client landscape in future years. California Updates Uniform Directed Trust Act and Uniform Fiduciary Income and Principal Act Become Effective As reported in Katten's 2023 Year-End Advisory , the California Uniform Directed Trust Act (UDTA) and the Uniform Fiduciary Income and Principal Act (UFIPA) became effective January 1, 2024. The UDTA provides a method for regulating directed trusts in California and establishes the duties and responsibilities of the non-trustee fiduciaries and directed trustees. The UFIPA includes specific changes to the California Probate Code that provide trustees greater flexibility in managing unitrusts, or converting an income trust to a unitrust (unless the trust qualifies for a special tax benefit or involves a fiduciary who is not an independent person), allows fiduciaries to allocate tax receipts and make trust distributions, and further expands the power of trust fiduciaries to make determinations concerning allocation of income and principal, among other changes to trust administration and judicial oversight of California fiduciaries. Increase to Small Estate Probate Procedures Assembly Bill 2016 (AB 2016) passed the California Legislature on August 29, 2024, and was approved by Governor Gavin Newsom on September 21, 2024. Under existing law, the Probate Court establishes procedures through which a successor of a decedent may, without petitioning the court for letters of administration or filing a petition to probate the decedent's will, dispose of a portion of a decedent's real and personal property if the gross value of the decedent's estate does not exceed $184,500, which amount is adjusted by the Judicial Council every three years. These summary procedures allow some estates or portions thereof to be distributed to heirs in order to avoid unnecessary delays and expenses related to court supervision. In recognition of the rising values of residences in the state, AB 2016 will materially change the small estate probate procedures in California. Specifically, AB 2016 will amend current law related to the transfer of real property and allow for the transfer of the primary residence of a decedent only via a Petition to Determine Succession to Real Property if the value of the real property does not exceed $750,000 – a significant increase from the current threshold of $184,500. While a petitioner is no longer able to include the decedent's personal property in a Petition to Determine Succession to Real Property, the Small Estate Affidavit procedure to transfer personal property of a decedent remains in place if the value of the property does not exceed $184,500. The proponents of the statutory change argue that the new law will ensure that average Californians can transfer their largest asset to their heirs without being forced to use the lengthy and costly probate process, ensuring the intergenerational transfer of assets, which is critical for low‐ and moderate‐income households to build wealth. However, the new law requires that a successor who files a Petition to Determine Succession to Real Property shall deliver notice of the petition to each intestate heir, beneficiary and devisee named in the petition – a complication that is not required under current law. The notice requirement will likely result in heirs making claims against the estate which will drive up the costs of administration. In addition, the law, as modified, is limited to a decedent's primary residence, whereas current law permits any real and personal property under the threshold to be summarily distributed. The bill will amend Probate Code Sections 13100-13101, 13150-13152 and 13154, will repeal Section 13158 and will become effective January 1, 2025. Strengthening of Regulations Concerning Professional Fiduciaries The California Legislature has approved Assembly Bill 2148 (AB 2148) which governs the Professional Fiduciaries Bureau and which will oversee and regulate those persons acting in the capacity of a professional fiduciary in California. Professional Fiduciaries are routinely appointed to protect the interests of adults with mental disabilities, minors, elderly persons, conservatees and fiduciaries, to assist such persons with administration of estates and trusts, representation in court and as may otherwise be needed. Professional fiduciaries are held to a higher fiduciary standard than a lay trustee or trust fiduciary as they are licensed and represent themselves as having advanced skills, expertise and knowledge related to such administration. AB 2148 seeks to address a gap in existing law by authorizing professional fiduciaries to organize as a "professional corporation" pursuant to the provisions of the Moscone Knox Professional Corporation Act. AB 2148 will require a professional fiduciary corporation to register with and be subject to the regulation of the Professional Fiduciaries Bureau and all other requirements under the Professional Fiduciaries Act. The bill will also prohibit a court from appointing a professional fiduciary to serve in any capacity unless such person is registered with the Professional Fiduciaries Bureau. California Supreme Court Makes Long-Awaited Ruling Concerning Approved Method of Trust Modification As previously reported, California courts have been split concerning the required procedure for modifying California revocable trusts since the Fourth District Court of Appeal handed down its decision in Haggerty v. Thornton (2021) 68 Cal.App.5th 1003. In Haggerty, the court concluded that unless a trust expressly provides that a particular method of modification is exclusive, the stated method is not required for a modification to be effective, and the statutory procedure for modification and revocation is an acceptable method of modifying the trust. The statutory provisions at issue in Haggerty are Probate Code sections 15401 and 15402, which govern modifications and revocations of California trusts. Section 15401 provides that a trust may be revoked by any method provided in the trust or by a writing, other than a will, signed by the settlor or any other person holding the power of revocation and delivered to the trustee during the lifetime of the settlor or person holding the power to revoke. The latter method of revocation is the "statutory" method. Section 15401 further provides that if the trust instrument explicitly makes the method of revocation provided in the trust instrument the exclusive method of revocation, then that method must be used to effectively revoke the trust. In contrast to Section 15401, Section 15402, which governs modification, provides simply that unless the trust instrument provides otherwise, if a trust is revocable by the settlor, the settlor may modify the trust by the procedure for revocation. Because the provisions concerning modification do not include the language concerning situations in which a settlor has made a specific method of modification the exclusive method, courts have come to vastly different rulings in deciding how California trusts may be modified. To wit, in stark contrast to the Fourth District's more lenient approach to modification in Haggerty , the Fifth District Court of Appeal in King v. Lynch (2012) 139 Cal.App.4th 1186, Third District Court of Appeal in Pena v. Dey (2019) 39 Cal.App.5th 546, First District Court of Appeal in Balistreri v. Balistreri (2022) 75 Cal.App.5th 511 and Second District Court of Appeal in Diaz v. Zuniga (2023) 91 Cal.App.5th 916 have all held that when a trust sets forth a method or procedure for trust modification, such designated method must be followed in order for a modification to be effective, regardless of whether the trust expressly provides that the designated method is the exclusive method of modification. On February 8, 2024, the California Supreme Court issued its opinion in Haggerty and resolved the circuit split in favor of the Fourth District's interpretation. The court held that the statutory method for revocation is available where the trust provides for a method of modification but does not expressly make the method exclusive, setting aside the King, Balistreri, Pena and Diaz decisions. As the California Supreme Court has now settled this issue, it is incumbent on California settlors who intend to control the method by which their trusts can be modified to provide an explicit statement in any trust instrument that directly sets forth the method of amendment or modification and which provides whether such procedure is the exclusive method by which the trust may be modified. Absent such explicit provision, a California revocable trust may be modified by a writing, other than a will, signed by the settlor or any other person holding the power of revocation and delivered to the trustee during the lifetime of the settlor or person holding the power to revoke. Illinois Updates Control and Protection of Trust Property On August 9, 2024, Senate Bill 3343 (SB 3343) was signed into law, which amends Sections 809 and 810 of the Illinois Trust Code. Section 809 of the Illinois Trust Code, titled "Control and Protection of Trust Property," currently requires that a trustee take reasonable steps to take control of and protect trust property. SB 3343 amends Section 809 of the Illinois Trust Code to specify that the trustee's duty includes "searching for and claiming any unclaimed or presumptively abandoned property." SB 3343 further amends Section 810 of the Illinois Trust Code, titled "Recordkeeping and Identification of Trust Property," to create additional duties for trustees terminating a trust. SB 3343 adds Section 810(e) of the Illinois Trust Code which will mandate that "[a] trustee shall maintain or cause to be maintained trust records for a minimum of seven years after the dissolution of the trust," and Section 810(f) of the Illinois Trust Code which will require that "[p]rior to the destruction of trust records, a trustee shall conduct a reasonable search for any trust property that is presumptively abandoned or that has been reported and remitted to a state unclaimed property administrator." similar amendment was initially proposed in January 2024 in HB 4320 but faced broad opposition and failed to proceed through the legislative process. Sections 809 and 810 of the Illinois Trust Code are now, however, amended through SB 3343. Other than these updates to the Illinois Trust Code, SB 3343 primarily amends the Revised Uniform Unclaimed Property Act. Early criticisms of SB 3343 include that the terms "trust records" and "reasonable search" are not defined, creating uncertainty. This amendment will have implications for, among others, corporate and individual trustees, including their legal, tax and other advisers. This amendment will take effect on January 1, 2025. Illinois Power of Attorney Act An amendment (Senate Bill 3421) to the Illinois Power of Attorney Act was signed by Illinois Governor J. B. Pritzker on August 9, 2024, and will take effect on January 1, 2025. This amendment states that it is unlawful for a third party to unreasonably refuse to accept an individual's Illinois statutory short form power of attorney for property which was executed in accordance with the laws in effect at the time of such power of attorney's execution. The amendment provides clarification for what "unreasonable" means by providing examples of when it is unreasonable for a third party to reject a properly executed Illinois statutory short-form power of attorney for property. The amendment also lists examples of reasonable causes to refuse to honor such power of attorney. Notably, it is unreasonable to refuse an Illinois statutory short form power of attorney for property because such power of attorney is not on a form the third party receiving such power prescribes or because of a lapse of time since the execution of the power of attorney. The amendment also lists 14 reasonable causes to refuse to honor an Illinois statutory short form power of attorney for property. Reasonable causes include actual knowledge or a reasonable basis for believing the agent is engaged in fraud or abuse of the principal as well as the refusal of the principal's attorney to provide a certificate that the power of attorney is valid. Illinois Notary Public Act Senate Bill 3513 (SB 3513) has been signed into law and amends the Illinois Notary Public Act to streamline the renewal process for notary publics who are attorneys, judges or their employees. This amendment states that licensed attorneys, judges or employees of attorneys or the court, may renew their appointments as notaries public (or electronic notaries public) without completing the course of study or passing the examination required for initial applicants. To take advantage of this streamlined renewal process, said individuals must instead submit a signed statement certifying that said person is a licensed attorney, judge, or employee of a licensed attorney or the court and that said individual has read and understands the Illinois Notary Public Act. This amendment seeks to ease burdens on legal professionals renewing their notary licenses. This amendment will take effect on January 1, 2025. Electronic Wills, Electronic Estate Planning Documents, and Remote Witnesses Act House Bill 2269 (HB 2269) went into effect on January 1, 2024. HB 2269 amends the Electronic Wills, Electronic Estate Planning Documents and Remote Witnesses Act, which governs electronic signature and electronic notarization procedures for "nontestamentary estate planning documents." Nontestamentary estate planning documents are broadly defined in the statute as records "relating to estate planning that [are] readable as text at the time of signing and [are] not a will or contained in a will." The statute provides a non-exhaustive list of examples of nontestamentary estate planning documents, including, but not limited to documents that create, exercise, modify, release or revoke (i) a trust, (ii) a trust power, (iii) a certification of trust, (iv) a power of attorney, (v) a power of appointment, (vi) an advanced directive, or (vii) a nomination of a guardian for the signing individual. HB 2269 explicitly overrides existing Illinois law to the contrary by providing that, even if other Illinois law "requires a nontestamentary estate planning document to be in writing, an electronic record of the document satisfies the requirement." However, practitioners may draft nontestamentary estate planning documents to preclude the use of electronic signatures or notarization on a document. These restrictions are valid and will void the electronic signature or notarization of such documents. It is important to be cognizant of and review for such restrictions before electronically signing a document. Under HB 2269, an electronic signature is attributable to a person if "it was the act of the person." This is a fact-intensive inquiry and may be shown "in any manner, including by showing the efficacy of a security procedure." A security procedure is defined as a procedure that can verify that the electronic signature is that of a specific person, including using an identifying word, number or code. Existing notary requirements remain in effect, but nontestamentary estate planning documents can be notarized remotely. If notarization is required, the notary must "associate the individual's electronic signature on the document together with all other information required to be included under other law." Witnesses may also remotely witness an individual's signature under this law. The requirement for witnesses is "electronic presence," which means that two or more people (i.e., the witness(es) and the individual signing the document) are able to communicate (i) in real-time and (ii) to the same extent as if they were in the same physical location. A live videoconference may satisfy these requirements. The language of HB 2269 was adopted from the Uniform Electronic Estate Planning Documents Act (the UEEPDA) which was recommended to the states by the Uniform Law Commission. Illinois is the first state to enact a version of the UEEPDA. The UEEPDA is ultimately intended to increase flexibility for the execution of nontestamentary estate planning documents and broaden the scope of prior legislation which allowed for remote signatures of wills. In re Estate of Stinnette , 2024 IL App (2d) 230174 (May 3, 2024) In Stinnette , the mother of the decedent, Zharvellis Holmes (Decedent's Mother), filed a petition for appointment as administrator of the decedent's estate. In such petition, Decedent's Mother filed an affidavit of heirship referring to a minor child, Marcellis Jr. (Potential Son), as the decedent's "potential son." Potential Son's mother, Tafara Williams (Potential Son's Mother), filed a counterpetition for appointment as administrator of the decedent's estate. The trial court granted Decedent's Mother's petition and denied Potential Son's Mother's counterpetition without conducting an evidentiary hearing regarding whether Potential Son was the decedent's biological son. Potential Son's Mother appealed the trial court's ruling, claiming that (i) Decedent's Mother lacked standing for the appointment as administrator since Decedent's Mother did not have an interest in the decedent's estate (arguing the testator died intestate leaving Potential Son as the decedent's sole heir), and (ii) the trial court failed to conduct an evidentiary hearing before appointing Decedent's Mother as the administrator. The appellate court first addressed the issue of whether, in an intestate matter, an individual must be interested in a decedent's estate to qualify as an administrator. The appellate court quickly dismissed this argument. The appellate court stated the administration of a decedent's estate is a creature of statute and that nothing in Illinois law, including the Probate Act of 1975 (the Illinois Probate Act), requires that an individual be interested in the decedent's estate to assume the duty of administrator. Section 9-1 of the Illinois Probate Act instead requires that such person has (i) attained the age of 18, (ii) is a resident of the United States, (iii) is not of unsound mind, (iv) is not an adjudged person with a disability (as defined in the Illinois Probate Act), and (v) has not been convicted of a felony. The appellate court next visited Potential Son's Mother's argument that the trial court failed to conduct an evidentiary hearing. Critical to the analysis of who should be appointed as administrator of an intestate estate is the order of preference listed in Section 9-3 of the Illinois Probate Act. Orders of preference rank the priority of individuals seeking to become the administrator of an individual's estate. Such order of preference in the Illinois Probate Act lists the children of a decedent prior to the parents of a decedent. Despite Decedent's Mother qualifying as a potential administrator under the Illinois Probate Act, Potential Son takes preference if it is proved that he is the decedent's biological son. The trial court granted Decedent's Mother's petition without conducting an evidentiary hearing as to whether Potential Son was the decedent's biological son, and thus, whether Potential Son had preference over Decedent's Mother under Section 9-3 of the Illinois Probate Act. The appellate court vacated the trial court's judgment and remanded for further proceedings. The appellate court held that the trial court erred by granting Decedent's Mother's petition before ruling on Potential Son's Mother's petition that Potential Son's Mother be appointed guardian of the decedent's estate and by failing to conduct an evidentiary hearing as to whether Potential Son was the decedent's biological son. In re Estate of McDonald , 2024 IL App (2d) 230195 (Apr. 15, 2024) In McDonald , the appellate court clarified whether putative-spouse claims are barred by the limitations provisions of Section 18-12(b) of the Illinois Probate Act. The appellate court also analyzed the "good faith belief" requirement of the putative-spouse doctrine, which had not previously been examined in great detail by an Illinois court. McDonald involves a decedent, John W. McDonald III (Decedent), who was disabled and in need of guardianship. In May 2017, Decedent's brother, Shawn McDonald (Decedent's Brother), was appointed as Decedent's plenary guardian of Decedent's person and estate. Decedent unsuccessfully moved to vacate the guardianship order. Decedent and his alleged putative spouse, Ellizzette McDonald (Putative Spouse) participated in a marriage ceremony approximately six weeks after Decedent's Brother was appointed plenary guardian. Deposition transcripts revealed that Putative Spouse knew, prior to the marriage ceremony, that Decedent was declared a ward of the court and that Decedent's Brother had been appointed as Decedent's plenary guardian. Decedent died intestate, and Decedent's Brother successfully filed a petition for letters of administration and an affidavit of heirship (in such pleadings, claiming that Decedent's marriage with Putative Spouse was void because Decedent, as a ward of the court, lacked the capacity to consent to the marriage). Putative Spouse moved to vacate the court's order appointing Decedent's Brother as administrator and asserted she was Decedent's surviving spouse and sole heir. The appellate court first addressed whether putative-spouse claims are barred by the limitations provisions of Section 18-12(b) of the Illinois Probate Act. Section 18-12(b) of the Illinois Probate Act provides that "... all claims which could have been barred under this Section are ... barred two years after decedent's death, whether or not letters of office are issued upon the estate of the decedent...." Putative Spouse argued that the word "claims" denotes claims against a decedent's estate which reduce the assets of the decedent's estate. Decedent's Brother countered that Section 18-12(b) of the Illinois Probate Act requires all claims against a decedent's estate be made within two years of the decedent's death. The appellate court decided with Decedent's Brother. The Illinois Probate Act broadly defines a "claim" as "any cause of action." As such, the two-year limitations provision applies to any claim regardless of its legal basis. The appellate court noted that the policy of strictly applying this limitations period facilitates the timely settlement of estates. The appellate court next addressed Putative Spouse's "good faith belief" argument under the putative-spouse doctrine. "[T]he rights of a putative spouse are conferred upon anyone who has gone through a marriage ceremony and cohabitated with another in the good-faith belief that he or she was married to the other individual." The appellate court does not explicitly adopt the standard of "good faith belief" set forth in Williams v. Williams, 97 P.3d 1124 (Nev. 2004) (a Nevada Supreme Court case) but does apply such standard. The standard in Williams is that when an alleged putative spouse receives "reliable information that an impendent [to a valid marriage] exists, the individual cannot ignore the information, but instead has a duty to investigate further. Persons cannot act 'blindly or without reasonable precaution.'" The appellate court held that even if Putative Spouse's claims were not barred under Section 18-12(b) of the Illinois Probate Act, her claims would fail under Williams. The appellate court took note that prior to the marriage ceremony, Putative Spouse was aware Decedent was a ward of the court and that Decedent's Brother had been appointed plenary guardian. Further, following the marriage ceremony, Putative Spouse was aware that an independent counsel had been appointed to represent Decedent and that said independent counsel had cautioned Decedent and Putative Spouse that potential impediments to marriage existed. The appellate court thus affirmed the lower court's ruling that Putative Spouse failed to present a prima facie case establishing the validity of her marriage to Decedent. New York Updates State Estate Taxation For individuals dying on or after January 1, 2025, the basic exclusion amount will be equal to the federal basic exclusion amount indexed annually, but without regard to the passage of the TCJA of 2017. New York Limited Liability Company Transparency Act On March 1, 2024, New York Governor Kathy Hochul signed into law the amended New York Limited Liability Company Transparency Act (NYLTA). The New York LLC Transparency Act requires limited liability companies (LLCs) formed under the New York LLC Act or doing business in New York State to provide certain informational filings to the New York State Secretary of State relating to the beneficial owners of such entity. The NYLTA is a state corollary to the CTA which is discussed in greater detail above in this advisory and incorporates many of the CTA's provisions. The requirements of the NYLTA are to take effect on January 1, 2026. The NYLTA originally included the creation of a publicly accessible online database where the full legal name and business address of each beneficial owner would be available. However, as part of the compromise between Governor Hochul and the New York State legislators championing the NYLTA, the provisions allowing for a publicly accessible database were removed, and the beneficial ownership information collected will now only be available to certain government and law enforcement agencies. Any LLC formed or authorized to do business in the state of New York on or after January 1, 2026, will be required to provide the informational filing within 30 days of formation or authorization to do business in New York. All pre-existing entities would be required to file such information with New York State by January 1, 2027, or otherwise upon any amendment to the LLC's filed organizational documents. Unlike the CTA, the NYLTA requires all reporting companies to file annual statements either confirming or updating their beneficial ownership information. Additionally, while the categories of entities that are exempt from reporting under the New York LLC Transparency Act are the same as those under the CTA, the NYLTA requires potentially exempt entities to file an attestation of exemption. Under the NYLTA, the Attorney General is authorized to investigate any LLC that does not provide its informational filing by the required date and may impose penalties of up to $500 for each day that the filing is late. Transfer on Death Deeds As part of the 2024-2025 Executive Budget, New York enacted a new law allowing for the use of transfer on death (TOD) deeds. A TOD deed allows the owner of real property to designate a beneficiary who will automatically inherit the property on their death, rather than having to receive such property as part of the probate process. The Transfer on Death Deed Law took effect on July 19, 2024, and is codified as Section 424 of the New York Real Property Law. To effectively utilize a TOD deed, the deed stating that the transfer to the designated beneficiary is to occur at the current property owner's death must be notarized and signed by two witnesses who were present at the same time and witnessed the property owner's signing of the deed. The TOD deed must also be recorded during the owner's lifetime in the county where the property is located. The utilization of a TOD deed allows the transfer of the property to happen outside of the often-drawn-out probate process without the transferor giving up current ownership and control. However, it allows for less flexibility in the administration of an estate where the real property may be needed to effectively execute other estate planning strategies and will not be appropriate in many more complex planning structures. Multi-Person Bank Accounts A new law has been proposed that aims to remedy the present issues regarding the treatment of multi-person bank accounts in New York. Currently, New York Banking Law (NYBL) Section 675 dictates that a deposit made into a joint account is considered to be owned in equal proportions by the account holders and, when the first of the account holders dies, the surviving account holder is considered to be the owner of the entire account. However, many joint accounts are opened merely for convenience purposes. A common example of a joint account used only for convenience is when an elderly parent and their adult child hold an account together so that the adult child can assist their parent in paying bills and generally managing the parent's funds. In this kind of situation, the intent is not for the parent to make a gift of one-half of the joint funds when deposited into the account or for the joint funds all to be left to the child upon their death, however, these are the presumed results under NYBL Section 675. The only exception to this is NYBL Section 678, which was created in recognition of these "convenience accounts." Under NYBL Section 678, upon creation, a second account holder can be added to an account with the designation of only being an account holder "for the convenience of" the person who actually deposits the funds into the account. If this designation is made, then there is no presumption of survivorship rights when the first account holder dies, and the funds are only considered to belong to the individual who deposited the funds into the account. Convenience accounts under NYBL Section 678, however, have never become widely used, mainly due to the fact that most individuals do not realize that this is a designation that must be made when creating a joint account for convenience purposes. The new law, NYBL Section 678-a, would replace the current NYBL Section 678, and NYBL Section 675 would only apply to those accounts created before the effective date of the law that are not modified to comply with NYBL Section 678-a after it becomes effective. Under NYBL Section 678-a, upon creation of a joint account, banks must require the account holders to complete a signature card that specifically establishes whether the account holders have survivorship rights or whether the account is for convenience only. NYBL Section 678-a also generally reverses the presumption of survivorship rights, so that an account created after the new law becomes effective will be presumed to be for convenience unless survivorship rights are designated on the signature card. Additionally, even if survivorship rights are designated, if there is clear and convincing evidence that survivorship was not actually intended, the account funds will still be allowed to pass under the decedent's estate. The bill (A.9230-B/S.9383A) has been passed in both houses of the New York State legislature and is awaiting delivery to Gov. Hochul. If signed, the new law will be effective starting July 1, 2025, and banks will be required to notify existing joint account holders of the new signature card requirement within six months of the effective date. Reduction in Recordkeeping Requirement for Notaries On January 31, 2023, a law went into effect permanently authorizing remote electronic notarization for certain documents and making the requirement to keep a detailed log of all notarizations performed for 10 years apply to all notaries, regardless of whether the notarial act was done remotely or in person. The extension of the recordkeeping requirement received backlash for being excessively time-consuming and burdensome. Additionally, attorneys who perform notarizations for their clients also raised concerns about the potential attorney-client privilege and confidentiality issues that could arise from keeping such records. As a result, a bill (A.7241/S.8663) has been proposed that exempts those notaries performing non-remote electronic notarizations from the new recordkeeping requirements. The bill has passed both houses but has not yet been delivered to Gov. Hochul for signature. Removal of Notary Requirement for Affidavits in Civil Matters An amendment to the New York Civil Practice Law and Rules went into effect on January 1, 2024, removing the requirement for notarized affidavits in civil matters, which includes those in the Surrogate's Court. Previously, only attorneys, physicians, osteopaths, dentists and persons located outside of the United States were authorized to submit affirmations in lieu of affidavits. Now, however, any person who wishes to file sworn statements in a civil proceeding may do so, so long as the person affirms the truth of their statement under the penalty of perjury. This greatly eases the burden of submitting a statement to the court, especially for those involved in time-sensitive proceedings. Remote Witnessing for Health Care Proxies In yet another move to reduce procedural burdens, New York Public Health Law Section 29812-a was enacted to allow for Health Care Proxies to be witnessed remotely. In order to properly conduct a remote witnessing for a Health Care Proxy, the law specifies that (i) if the witness does not personally know the principal, they must be shown a valid photo ID; (ii) the execution of the document must be done using audio-visual conferencing technology that allows for direct interaction between the principal and any remote witness; (iii) a legible copy of the document must be transmitted to any remote witness within 24 hours of the execution; and (iv) any remote witness must sign the transmitted copy and return it to the principal. North Carolina Updates Remote Electronic Notary Act As discussed in last year's advisory, the North Carolina Remote Electronic Notary Act (referred to as RENA or the Act) was enacted on July 8, 2022. This Act permanently codified remote electronic notarization (REN) and restored North Carolina's "temporary" emergency video notarization and remote video witnessing (EVN). The Act initially provided that the temporary EVN laws would expire on June 30, 2023, when the REN provisions became effective. This one-year period was intended to give the North Carolina Secretary of State time to make preparations and adopt relevant rules and regulations to implement the law. On June 23, 2023, Governor Roy Cooper enacted amendments to the Notary Act under North Carolina General Statutes (NCGS) Chapter 10B. These amendments are generally changes to RENA, as well as responses to public comments to the North Carolina Secretary of State's Advance Notices of Proposed Rulemaking and Requests for Public Comment. Below is a summary of the most important changes: Extension of Emergency Video Notarization and Emergency Video Witnessing and Delay of Remote Electronic Notarization. The effective date for "permanent" REN was changed from July 1, 2023, to July 1, 2024. As a result, the "temporary" EVN rules were extended until June 30, 2024. The EVN provisions were not extended past this date. Currently, notaries may not perform Remote Electronic Notarizations until the rules implementing the Act have been adopted. As of the date of this publication, rulemaking is still in progress. Therefore, there is currently no remote electronic notarization, emergency video notarization, or remote witnessing provisions in effect. As noted in last year's advisory, there are several important differences between RENA and remote notarization and witnessing under EVN: EVN allows the execution of estate planning documents, but RENA specifically excludes wills and trusts. EVN allows for remote witnessing, but RENA does not include a provision for remote electronic witnessing that applies after June 30, 2024. Therefore, remote video witnessing is currently not permitted. Changes to Journal Requirements. The Act required all notaries to maintain a journal of all notarial acts performed. This requirement applies to all notaries, not just electronic notaries. However, S.L. 2023-124, which was signed into law on September 28, 2023, provides that only an electronic notary who performs a remote electronic notarization shall maintain an electronic journal. Other notaries are not required to maintain a journal. Remote Notary Authorization Changes. The amendment modifies various definitions sections to clarify that an electronic notary is a notary authorized to perform in-person electronic notarial acts as well as remote electronic notarial acts, and also adds defined terms for geolocation, remotely located principal and self-attestation. The Act also requires that an electronic notary must register with the Secretary before performing any electronic notarial act. There are certain documents that an electronic notary is barred from notarizing. Death beneficiary forms that require acknowledgment have been removed from this list of documents. Therefore, the amended list of excluded documents includes: A self-proved will executed pursuant to Article 4A of Chapter 31 of the General Statutes. A revocable or irrevocable trust or any other document amending the same except for a certification of trust or similar document. A codicil to a will. Any document related to the relinquishment of parental rights under Article 3 of Chapter 48 of the General Statutes. Spousal and Child's Allowance Updates Session Law 2023-120 was signed into law on September 14, 2023, updating the spousal and child's allowance statutes (i.e., years allowances). Generally, the updated statutes aim to provide a simplified procedure for the filing of petitions and awarding of allowances. Among other changes, the new law also confirms that a surviving spouse has priority in the satisfaction of an allowance if multiple requests are made. The new law also provides that the child's allowance is available to all children under age 21 and increases the child's allowance to $10,000. These new laws were effective on March 1, 2024, and apply to decedents dying on or after March 1, 2024. Treatment of Former Spouses in Will and Trust Following Divorce Session Law 2023-120 sought to equalize the treatment of divorced spouses in a will under North Carolina law and under the North Carolina Uniform Trust Code. Pursuant to new NCGS 31-5.4, after a divorce, a former spouse will be deemed to have predeceased the testator for all purposes under a will. The updated law provides that the statute does not apply if the spouses remarry each other before the death of the testator. In addition, the statute does not apply if the testator executes a subsequent valid will or other testamentary document that makes express reference to the will and that modifies the will. The corresponding section of the North Carolina Uniform Trust Code (Section 36C-6-606) was updated to conform to the new NCGS 31-5.4. In addition, S.L. 2023-120 adds a provision stating that the statute does not apply to a revocable trust if the settlor executes a valid amendment to the revocable trust after a divorce. This language conforms to the updated NCGS 31-5.4. The law also carried forward the provision from the former statute that the statute will not apply if the spouses remarry each other before the settlor's death. These new laws became effective on March 1, 2024, and apply to wills probated on or after that date. Texas Updates It has been a quiet year in Texas on the Private Wealth front as the Texas State Legislature enjoyed its biennial recess. Nevertheless, Texas' increasingly business-friendly environment saw some activity with its special new courts. Last year, we reported that the Texas legislature established special courts to oversee complex business cases. In particular, the new business courts have jurisdiction over the following: Disputes over $5 million that involve various corporate affairs, such as derivative actions, actions by a business or its owner against another officer or owner, and actions to hold owners or executives responsible for breaches of duty; cases involving publicly traded companies, regardless of the amount in question; and cases in excess of $10 million that involve contracts or commercial transactions and where the parties consent to the business courts' jurisdiction. Certain classes of disputes are expressly outside of the business courts' jurisdiction. For example, the business courts may not hear cases brought under the Texas Family Code, Estates Code, Insurance Code and Title 9 of the Property Code, nor medical and legal malpractice, personal injury or insurance coverage cases. Five business court divisions opened on September 1, 2024, in Dallas, Austin, San Antonio, Fort Worth and Houston, and Texas Governor Greg Abbott has appointed two judges to each court. At the time of publication, it is too early to tell what impact these new business courts will have, though we expect to have more developments in 2025. Additionally, 2024 saw new changes implemented to Texas' Franchise Tax. By way of background, Texas imposes a franchise tax on business entities – including LLCs, C Corporations, S Corporations, limited and general partnerships, etc. – formed or doing business in the state. In general, the franchise tax is levied at a rate of 0.75 percent on an entity's taxable margin. However, no tax was historically due when an entity's annualized revenue was less than $1.23 million. Even if the entity was not subject to the franchise tax, it was still required to submit a timely No Tax Due Report. In 2024, though, the minimum threshold increased to $2.47 million. In addition, entities that do not meet the taxable threshold are no longer required to submit a No Tax Due Report, thereby simplifying and reducing the cost of tax compliance. We look forward to next year's report, as there should be an abundance of activity once the Texas legislature is back in session in 2025. Florida Updates Right-to-Know for Denial of Homestead Exemptions Florida is one of a few states in the nation that allows for a property tax break for taxpayers who have a Florida home as their primary residence (otherwise known as a "homestead exemption"). To qualify for the homestead exemption, a taxpayer must annually file for such exemption with the Florida Department of Revenue. As of July 1, 2024, if a property appraiser makes a determination that a taxpayer is not entitled to the homestead exemption from property tax, such appraiser must include with its determination information that (i) explains why the taxpayer is not entitled to such exemption; (ii) lists the years for which unpaid taxes, penalties and interest are due; and (iii) how the unpaid taxes, penalties and interest have been calculated. Relatedly, additional legislation was passed, effective as of July 1, 2024, and applicable beginning with the 2025 tax roll, which provides that in instances in which a homestead exemption is granted because of a clerical mistake or omission by the property appraiser, the taxpayer will not owe any penalty or interest on the unpaid property taxes that are determined to be due. Additionally, if the taxpayer voluntarily discloses to the property appraiser that the homestead exemption was erroneously granted before the property appraiser notifies the taxpayer of the mistake or omission, no back taxes are due in connection with the unpaid property taxes. Florida Uniform Fiduciary Income and Principal Act The enactment of the Florida Uniform Fiduciary Income and Principal Act (FUFIPA) replaces the currently controlling Florida Uniform Principal and Income Act (FUPIA), which governs the default allocation of trust and estate receipts and disbursements between principal and interest for trusts and estates with a principal place of administration in Florida. This act, which goes into effect on January 1, 2025, is intended to modernize Florida's trust and estates law. FUFIPA encourages the use of modern portfolio theory for investments by fiduciaries, which emphasizes capturing the total return on both income and principal appreciation. The fiduciary is also authorized to make adjustments between income and principal under certain circumstances, providing greater flexibility to fiduciaries to administer trusts for an extended term for the benefit of current and remainder beneficiaries. This is important considering the rule against perpetuities in Florida was extended in 2022 to a 1,000-year period. Such adjustments may also be made when administering a unitrust if such adjustments will assist the fiduciary in administering the unitrust in an impartial manner. If a court determines that a fiduciary has abused their discretion in exercising the powers available to them under FUFIPA, the harmed beneficiaries are entitled to restore such beneficiaries to the positions they would have been in but for the fiduciary's abuse of discretion. Supported Decision-Making As of July 1, 2024, Florida now has authority allowing for supported decision-making by individuals with developmental disabilities who have not been adjudicated as incapacitated. The law provides for supported decision-making agreements that allow such developmentally disabled individuals to designate an agent to receive information and communicate on behalf of such individual with third parties but, unlike a durable power of attorney, does not allow the agent to make any decisions on such individual's behalf. This legislation is intended to benefit individuals who can live and work independently but may need some assistance with their decision-making without handing the ultimate control over a decision to a guardian or agent. In Conclusion: We Can Help We hope that this advisory helps you with your year-end estate and gift tax planning, and provides you with some interesting ideas to consider for the future. As always, the Katten Private Wealth practice stands ready and able to assist you with these matters at any time.

LONDON — Olivia Hussey, the actor who starred as a teenage Juliet in the 1968 film "Romeo and Juliet," died, her family said on social media Saturday. She was 73. Hussey died Friday "peacefully at home surrounded by her loved ones," a statement posted to her Instagram account said. Hussey was 15 when director Franco Zeffirelli cast her in his adaptation of the William Shakespeare tragedy after spotting her onstage in the play "The Prime of Miss Jean Brodie," which also starred Vanessa Redgrave. "Romeo and Juliet" won two Oscars and Hussey won a Golden Globe for best new actress for her part as Juliet, opposite British actor Leonard Whiting, who was 16 at the time. "Romeo and Juliet" movie director Franco Zeffirelli, left, and actors Olivia Hussey, center, and Leonard Whiting are seen Sept. 25, 1968, in Paris after the Parisian premiere of the film. Decades later Hussey and Whiting brought a lawsuit against Paramount Pictures alleging sexual abuse, sexual harassment and fraud over nude scenes in the film. They alleged they were initially told they would wear flesh-colored undergarments in a bedroom scene, but on the day of the shoot Zeffirelli told the pair they would wear only body makeup and the camera would be positioned in a way that would not show nudity. They alleged they were filmed in the nude without their knowledge. The case was dismissed by a Los Angeles County judge in 2023, who found their depiction could not be considered child pornography and the pair filed their claim too late. Leonard Whiting, left, and Olivia Hussey arrive April 26, 2018, at the screening of "The Producers" at the 2018 TCM Classic Film Festival Opening Night at the TCL Chinese Theatre in Los Angeles. Whiting was among those who paid tribute to Hussey on Saturday. "Rest now my beautiful Juliet no injustices can hurt you now," he wrote. "And the world will remember your beauty inside and out forever." Hussey was born April 17, 1951, in Bueno Aires, Argentina, and moved to London as a child. She studied at the Italia Conti Academy drama school. She also starred as Mary, the mother of Jesus, in the 1977 television series "Jesus of Nazareth," as well as the 1978 adaptation of Agatha Christie's "Death on the Nile" and horror movies "Black Christmas" and "Psycho IV: The Beginning." She is survived by her husband, David Glen Eisley, her three children and a grandson. Germany players celebrate after Andreas Brehme, left on ground, scores the winning goal in the World Cup soccer final match against Argentina, in the Olympic Stadium, in Rome, July 8, 1990. Andreas Brehme, who scored the only goal as West Germany beat Argentina to win the 1990 World Cup final, died Feb. 20, 2024. He was 63. Brian Mulroney, the former prime minister of Canada, listens during a Senate Foreign Relations Committee hearing on the Canada-U.S.-Mexico relationship, Tuesday, Jan. 30, 2018, on Capitol Hill in Washington. Mulroney died at the age of 84 on Feb. 29, 2024. The Rev. James Lawson Jr. speaks Sept. 17, 2015, in Murfreesboro, Tenn. Lawson Jr., an apostle of nonviolent protest who schooled activists to withstand brutal reactions from white authorities as the Civil Rights Movement gained traction, has died, his family said Monday. He was 95. His family said Lawson died on Sunday after a short illness in Los Angeles, where he spent decades working as a pastor, labor movement organizer and university professor. Lawson was a close adviser to the Rev. Martin Luther King Jr., who called him “the leading theorist and strategist of nonviolence in the world.” Lawson met King in 1957, after spending three years in India soaking up knowledge about Mohandas K. Gandhi’s independence movement. King would travel to India himself two years later, but at the time, he had only read about Gandhi in books. Basketball Hall of Fame inductee Jerry West, representing the 1960 USA Olympic Team, is seen Aug. 13, 2010, during the enshrinement news conference at the Hall of Fame Museum in Springfield, Mass. Jerry West, who was selected to the Basketball Hall of Fame three times in a storied career as a player and executive, and whose silhouette is considered to be the basis of the NBA logo, died June 12, the Los Angeles Clippers announced. He was 86. West, nicknamed “Mr. Clutch” for his late-game exploits as a player, was an NBA champion who went into the Hall of Fame as a player in 1980 and again as a member of the gold medal-winning 1960 U.S. Olympic Team in 2010. He will be enshrined for a third time later this year as a contributor, and NBA Commissioner Adam Silver called West “one of the greatest executives in sports history.” Actor and director Ron Simons, seen Jan. 23, 2011, during the 2011 Sundance Film Festival, died June 12. Simons turned into a formidable screen and stage producer, winning four Tony Awards and having several films selected at the Sundance Film Festival. He won Tonys for producing “Porgy and Bess,” “A Gentleman’s Guide to Love and Murder,” “Vanya and Sonia and Masha and Spike,” and “Jitney.” He also co-produced “Hughie,” with Forest Whitaker, “The Gin Game,” starring Cicely Tyson and James Earl Jones, “Ain’t Too Proud: The Life and Times of The Temptations,” an all-Black production of “A Streetcar Named Desire,” the revival of "for colored girls who have considered suicide/when the rainbow is enuf" and the original work “Thoughts of a Colored Man.” He was in the films “27 Dresses” and “Mystery Team,” as well as on the small screen in “The Resident,” “Law & Order,” “Law & Order: Criminal Intent” and “Law & Order: SVU.” Bob Schul of West Milton, Ohio, hits the tape Oct. 18, 1964, to win the 5,000 meter run at the Olympic Games in Tokyo. Schul, the only American distance runner to win the 5,000 meters at the Olympics, died June 16. He was 86. His death was announced by Miami University in Ohio , where Schul shined on the track and was inducted into the school’s hall of fame in 1973. Schul predicted gold leading into the 1964 Tokyo Olympics and followed through with his promise. On a rainy day in Japan, he finished the final lap in a blistering 54.8 seconds to sprint to the win. His white shorts were covered in mud at the finish. He was inducted into the USA Track and Field Hall of Fame in 1991. He also helped write a book called “In the Long Run.” San Francisco Giants superstar Willie Mays poses for a photo during baseball spring training in 1972. Mays, the electrifying “Say Hey Kid” whose singular combination of talent, drive and exuberance made him one of baseball’s greatest and most beloved players, died June 18. He was 93. The center fielder, who began his professional career in the Negro Leagues in 1948, had been baseball’s oldest living Hall of Famer. He was voted into the Hall in 1979, his first year of eligibility, and in 1999 followed only Babe Ruth on The Sporting News’ list of the game’s top stars. The Giants retired his uniform number, 24, and set their AT&T Park in San Francisco on Willie Mays Plaza. Mays died two days before a game between the Giants and St. Louis Cardinals to honor the Negro Leagues at Rickwood Field in Birmingham , Alabama. Over 23 major league seasons, virtually all with the New York/San Francisco Giants but also including one in the Negro Leagues, Mays batted .301, hit 660 home runs, totaled 3,293 hits, scored more than 2,000 runs and won 12 Gold Gloves. He was Rookie of the Year in 1951, twice was named the Most Valuable Player and finished in the top 10 for the MVP 10 other times. His lightning sprint and over-the-shoulder grab of an apparent extra base hit in the 1954 World Series remains the most celebrated defensive play in baseball history. For millions in the 1950s and ’60s and after, the smiling ballplayer with the friendly, high-pitched voice was a signature athlete and showman during an era when baseball was still the signature pastime. Awarded the Medal of Freedom by President Barack Obama in 2015, Mays left his fans with countless memories. But a single feat served to capture his magic — one so untoppable it was simply called “The Catch.” Actor Donald Sutherland appears Oct. 13, 2017, at the Academy of Motion Picture Arts and Sciences in Beverly Hills, Calif. Sutherland, the Canadian actor whose wry, arrestingly off-kilter screen presence spanned more than half a century of films from “M.A.S.H.” to “The Hunger Games,” died June 20. He was 88. Kiefer Sutherland said on X he believed his father was one of the most important actors in the history of film: “Never daunted by a role, good, bad or ugly. He loved what he did and did what he loved, and one can never ask for more than that.” The tall and gaunt Sutherland, who flashed a grin that could be sweet or diabolical, was known for offbeat characters like Hawkeye Pierce in Robert Altman's "M.A.S.H.," the hippie tank commander in "Kelly's Heroes" and the stoned professor in "Animal House." Before transitioning into a long career as a respected character actor, Sutherland epitomized the unpredictable, antiestablishment cinema of the 1970s. He never stopped working, appearing in nearly 200 films and series. Over the decades, Sutherland showed his range in more buttoned-down — but still eccentric — roles in Robert Redford's "Ordinary People" and Oliver Stone's "JFK." More, recently, he starred in the “Hunger Games” films. A memoir, “Made Up, But Still True,” is due out in November. Actor Bill Cobbs, a cast member in "Get Low," arrives July 27, 2010, at the premiere of the film in Beverly Hills, Calif. Cobbs, the veteran character actor who became a ubiquitous and sage screen presence as an older man, died June 25. He was 90. A Cleveland native, Cobbs acted in such films as “The Hudsucker Proxy,” “The Bodyguard” and “Night at the Museum.” He made his first big-screen appearance in a fleeting role in 1974's “The Taking of Pelham One Two Three." He became a lifelong actor with some 200 film and TV credits. The lion share of those came in his 50s, 60s, and 70s, as filmmakers and TV producers turned to him again and again to imbue small but pivotal parts with a wizened and worn soulfulness. Cobbs appeared on television shows including “The Sopranos," “The West Wing,” “Sesame Street” and “Good Times.” He was Whitney Houston's manager in “The Bodyguard” (1992), the mystical clock man of the Coen brothers' “The Hudsucker Proxy” (1994) and the doctor of John Sayles' “Sunshine State” (2002). He played the coach in “Air Bud” (1997), the security guard in “Night at the Museum” (2006) and the father on “The Gregory Hines Show." Cobbs rarely got the kinds of major parts that stand out and win awards. Instead, Cobbs was a familiar and memorable everyman who left an impression on audiences, regardless of screen time. He won a Daytime Emmy Award for outstanding limited performance in a daytime program for the series “Dino Dana” in 2020. Independent gubernatorial candidate Kinky Friedman speaks with the media Nov. 7, 2009, at his campaign headquarters in Austin, Texas. The singer, songwriter, satirist and novelist, who led the alt-country band Texas Jewboys, toured with Bob Dylan, sang with Willie Nelson, and dabbled in politics with campaigns for Texas governor and other statewide offices, died June 27. He was 79 and had suffered from Parkinson's disease. Often called “The Kinkster" and sporting sideburns, a thick mustache and cowboy hat, Friedman earned a cult following and reputation as a provocateur throughout his career across musical and literary genres. In the 1970s, his satirical country band Kinky Friedman and the Texas Jewboys wrote songs with titles such as “They Ain't Makin' Jews Like Jesus Anymore” and “Get Your Biscuits in the Oven and Your Buns in Bed.” Friedman joined part of Bob Dylan's Rolling Thunder Revue tour in 1976. By the 1980s, Friedman was writing crime novels that often included a version of himself, and he wrote a column for Texas Monthly magazine in the 2000s. Friedman's run at politics brought his brand of irreverence to the serious world of public policy. In 2006, Friedman ran for governor as an independent in a five-way race that included incumbent Republican Rick Perry. Friedman launched his campaign against the backdrop of the Alamo. Martin Mull participates in "The Cool Kids" panel during the Fox Television Critics Association Summer Press Tour on Aug. 2, 2018, at The Beverly Hilton hotel in Beverly Hills, Calif. Mull, whose droll, esoteric comedy and acting made him a hip sensation in the 1970s and later a beloved guest star on sitcoms including “Roseanne” and “Arrested Development,” died June 28. He was 80. Mull, who was also a guitarist and painter, came to national fame with a recurring role on the Norman Lear-created satirical soap opera “Mary Hartman, Mary Hartman,” and the starring role in its spinoff, “Fernwood Tonight." His first foray into show business was as a songwriter, penning the 1970 semi-hit “A Girl Named Johnny Cash” for singer Jane Morgan. He would combine music and comedy in an act that he brought to hip Hollywood clubs in the 1970s. Mull often played slightly sleazy, somewhat slimy and often smarmy characters as he did as Teri Garr's boss and Michael Keaton's foe in 1983's “Mr. Mom.” He played Colonel Mustard in the 1985 movie adaptation of the board game “Clue,” which, like many things Mull appeared in, has become a cult classic. The 1980s also brought what many thought was his best work, “A History of White People in America,” a mockumentary that first aired on Cinemax. Mull co-created the show and starred as a “60 Minutes” style investigative reporter investigating all things milquetoast and mundane. Willard was again a co-star. In the 1990s he was best known for his recurring role on several seasons on “Roseanne,” in which he played a warmer, less sleazy boss to the title character, an openly gay man whose partner was played by Willard, who died in 2020 . Mull would later play private eye Gene Parmesan on “Arrested Development,” a cult-classic character on a cult-classic show, and would be nominated for an Emmy, his first, in 2016 for a guest run on “Veep.” Screenwriter Robert Towne poses at The Regency Hotel, March 7, 2006, in New York. Towne, the Oscar-winning screenplay writer of "Shampoo," "The Last Detail" and other acclaimed films whose work on "Chinatown" became a model of the art form and helped define the jaded allure of his native Los Angeles, died Monday, July 1, 2024, surrounded by family at his home in Los Angeles, said publicist Carri McClure. She declined to comment on any cause of death. Vic Seixas of the United States backhands a volley from Denmark's Jurgen Ulrich in the first round of men's singles match at Wimbledon, England, June 27, 1967. Vic Seixas, a Wimbledon winner and tennis Hall of Famer who was the oldest living Grand Slam champion, has died July 5 at the age of 100. The International Tennis Hall of Fame announced Seixas’ death on Saturday July 6, 2024, based on confirmation from his daughter Tori. In this June 30, 2020, file photo, Sen. James Inhofe, R-Okla., speaks to reporters following a GOP policy meeting on Capitol Hill in Washington. Former Sen. Jim Inhofe of Oklahoma died July 9. He was 89. The family says in a statement that the Republican had a stroke during the July Fourth holiday and died Tuesday morning. Inhofe was a powerful fixture in state politics for decades. He doubted that climate change was caused by human activity, calling the theory “the greatest hoax ever perpetrated on the American people.” As Oklahoma’s senior U.S. senator, he was a staunch supporter of the state’s military installations. He was elected to a fifth Senate term in 2020 and stepped down in early 2023. The Oak Ridge Boys, from left, Joe Bonsall, Richard Sterban, Duane Allen and William Lee Golden hold their awards for Top Vocal Group and Best Album of the Year for "Ya'll Come Back Saloon", during the 14th Annual Academy of Country Music Awards in Los Angeles, Calif., May 3, 1979. Bonsall died on July 9, 2024, from complications of Amyotrophic Lateral Sclerosis in Hendersonville, Tenn. He was 76. A Philadelphia native and resident of Hendersonville, Tennessee, Bonsall joined the Oak Ridge Boys in 1973, which originally formed in the 1940s. He saw the band through its golden period in the '80s and beyond, which included their signature 1981 song “Elvira.” The hit marked a massive crossover moment for the group, reaching No. 1 on the country chart and No. 5 on Billboard’s all-genre Hot 100. The group is also known for such hits as 1982’s “Bobbie Sue." Shelley Duvall poses for photographers at the 30th Cannes Film Festival in France, May 27, 1977. Duvall, whose wide-eyed, winsome presence was a mainstay in the films of Robert Altman and who co-starred in Stanley Kubrick's “The Shining,” died July 11. She was 75. Dr. Ruth Westheimer holds a copy of her book "Sex for Dummies" at the International Frankfurt Book Fair 'Frankfurter Buchmesse' in Frankfurt, Germany, Thursday, Oct. 11, 2007. Westheimer, the sex therapist who became a pop icon, media star and best-selling author through her frank talk about once-taboo bedroom topics, died on July 12, 2024. She was 96. Richard Simmons sits for a portrait in Los Angeles, June 23, 1982. Simmons, a fitness guru who urged the overweight to exercise and eat better, died July 13 at the age of 76. Simmons was a court jester of physical fitness who built a mini-empire in his trademark tank tops and short shorts by urging the overweight to exercise and eat better. Simmons was a former 268-pound teen who shared his hard-won weight loss tips as the host of the Emmy-winning daytime “Richard Simmons Show" and the “Sweatin' to the Oldies” line of exercise videos, which became a cultural phenomenon. Former NFL receiver Jacoby Jones died July 14 at age 40. Jones' 108-yard kickoff return in 2013 remains the longest touchdown in Super Bowl history. The Houston Texans were Jones’ team for the first five seasons of his career. They announced his death on Sunday. In a statement released by the NFL Players Association, his family said he died at his home in New Orleans. A cause of death was not given. Jones played from 2007-15 for the Texans, Baltimore Ravens, San Diego Chargers and Pittsburgh Steelers. He made several huge plays for the Ravens during their most recent Super Bowl title season, including that kick return. The "Beverly Hills, 90210" star whose life and career were roiled by tabloid stories, Shannen Doherty died July 13 at 53. Doherty's publicist said the actor died Saturday following years with breast cancer. Catapulted to fame as Brenda in “Beverly Hills, 90210,” she worked in big-screen films including "Mallrats" and "Jay and Silent Bob Strike Back" and in TV movies including "A Burning Passion: The Margaret Mitchell Story," in which she played the "Gone with the Wind" author. Doherty co-starred with Holly Marie Combs and Alyssa Milano in the series “Charmed” from 1998-2001; appeared in the “90210” sequel series seven years later and competed on “Dancing with the Stars” in 2010. Actor James Sikking poses for a photograph at the Los Angeles gala celebrating the 20th anniversary of the National Organization for Women, Dec. 1, 1986. Sikking, who starred as a hardened police lieutenant on “Hill Street Blues” and as the titular character's kindhearted dad on “Doogie Howser, M.D.,” died July 13 of complications from dementia, his publicist Cynthia Snyder said in a statement. He was 90. Pat Williams chats with media before the 2004 NBA draft in Orlando, Fla. Williams, a co-founder of the Orlando Magic and someone who spent more than a half-century working within the NBA, died July 17 from complications related to viral pneumonia. The team announced the death Wednesday. Williams was 84. He started his NBA career as business manager of the Philadelphia 76ers in 1968, then had stints as general manager of the Chicago Bulls, the Atlanta Hawks and the 76ers — helping that franchise win a title in 1983. Williams was later involved in starting the process of bringing an NBA team to Orlando. The league’s board of governors granted an expansion franchise in 1987, and the team began play in 1989. Lou Dobbs speaks Feb. 24, 2017, at the Conservative Political Action Conference in Oxon Hill, Md. Dobbs, the conservative political pundit and veteran cable TV host who was a founding anchor for CNN and later was a nightly presence on Fox Business Network for more than a decade, died July 18. He was 78. His death was announced in a post on his official X account, which called him a “fighter till the very end – fighting for what mattered to him the most, God, his family and the country.” He hosted “Lou Dobbs Tonight” on Fox from 2011 to 2021, following two separate stints at CNN. No cause of death was given. Bob Newhart, center, poses with members of the cast and crew of the "Bob Newhart Show," from top left, Marcia Wallace, Bill Daily, Jack Riley, and, Suzanne Pleshette, foreground left, and Dick Martin at TV Land's 35th anniversary tribute to "The Bob Newhart Show" on Sept. 5, 2007, in Beverly Hills, Calif. Newhart has died at age 94. Jerry Digney, Newhart’s publicist, says the actor died July 18 in Los Angeles after a series of short illnesses. The accountant-turned-comedian gained fame with a smash album and became one of the most popular TV stars of his time. Newhart was a Chicago psychologist in “The Bob Newhart Show” in the 1970s and a Vermont innkeeper on “Newhart” in the 1980s. Both shows featured a low-key Newhart surrounded by eccentric characters. The second had a twist ending in its final show — the whole series was revealed to have been a dream by the psychologist he played in the other show. Cheng Pei-pei, a Chinese-born martial arts film actor who starred in Ang Lee’s “Crouching Tiger, Hidden Dragon,” died July 17 at age 78. Her family says Cheng, who had been diagnosed with a rare illness with symptoms similar to Parkinson’s disease, passed away Wednesday at home surrounded by her loved ones. The Shanghai-born film star became a household name in Hong Kong, once dubbed the Hollywood of the Far East, for her performances in martial arts movies in the 1960s. She played Jade Fox, who uses poisoned needles, in “Crouching Tiger, Hidden Dragon,” which was released in 2000, grossed $128 million in North America and won four Oscars. Abdul “Duke” Fakir holds his life time achievement award backstage at the 51st Annual Grammy Awards on Feb. 8, 2009, in Los Angeles. The last surviving original member of the Four Tops died July 22. Abdul “Duke” Fakir was 88. He was a charter member of the Motown group along with lead singer Levi Stubbs, Renaldo “Obie" Benson and Lawrence Payton. Between 1964 and 1967, the Tops had 11 top 20 hits and two No. 1′s: “I Can’t Help Myself (Sugar Pie Honey Bunch)” and the operatic classic “Reach Out I’ll Be There.” Other songs, often stories of romantic pain and longing, included “Baby I Need Your Loving,” “Standing in the Shadows of Love,” “Bernadette” and “Just Ask the Lonely.” Sculptress Elizabeth Catlett, left, then-Washington D.C. Mayor Sharon Pratt Dixon, center, and then-curator, division of community life, Smithsonian institution Bernice Johnson Reagon chat during the reception at the Candace awards on June 25, 1991 in New York. Reagon, a musician and scholar who used her rich, powerful contralto voice in the service of the American Civil Rights Movement and human rights struggles around the world, died on July 16, 2024, according to her daughter's social media post. She was 81. John Mayall, the British blues musician whose influential band the Bluesbreakers was a training ground for Eric Clapton, Mick Fleetwood and many other superstars, died July 22. He was 90. He is credited with helping develop the English take on urban, Chicago-style rhythm and blues that played an important role in the blues revival of the late 1960s. A statement on Mayall's official Instagram page says he died Monday at his home in California. Though Mayall never approached the fame of some of his illustrious alumni, he was still performing in his late 80s, pounding out his version of Chicago blues. Erica Ash, an actor and comedian skilled in sketch comedy who starred in the parody series “Mad TV” and “Real Husbands of Hollywood,” has died. She was 46. Her publicist and a statement by her mother, Diann, says Ash died July 28 in Los Angeles of cancer. Ash impersonated Michelle Obama and Condoleeza Rice on “Mad TV,” a Fox sketch series, and was a key performer on the Rosie O’Donnell-created series “The Big Gay Sketch Show.” Her other credits included “Scary Movie V,” “Uncle Drew” and the LeBron James-produced basketball dramedy “Survivor’s Remorse.” On the BET series “Real Husbands of Hollywood,” Ash played the ex-wife of Kevin Hart’s character. Jack Russell, the lead singer of the bluesy '80s metal band Great White whose hits included “Once Bitten Twice Shy” and “Rock Me” and was fronting his band the night 100 people died in a 2003 nightclub fire in Rhode Island, died Wednesday, Aug. 7, 2024. He was 63. Juan “Chi Chi” Rodriguez, a Hall of Fame golfer whose antics on the greens and inspiring life story made him among the sport’s most popular players during a long professional career, died Thursday, Aug. 8, 2024. Susan Wojcicki, the former YouTube chief executive officer and longtime Google executive, died Friday, Aug. 9, 2024, after suffering with non small cell lung cancer for the past two years. She was 56. Frank Selvy, an All-America guard at Furman who scored an NCAA Division I-record 100 points in a game and later played nine NBA seasons, died Tuesday, Aug. 13, 2024. He was 91. Wallace “Wally” Amos, the creator of the cookie empire that took his name and made it famous and who went on to become a children’s literacy advocate, died Tuesday, Aug. 13, 2024, from complications with dementia. He was 88. Gena Rowlands, hailed as one of the greatest actors to ever practice the craft and a guiding light in independent cinema as a star in groundbreaking movies by her director husband, John Cassavetes, and who later charmed audiences in her son's tear-jerker “The Notebook,” died Wednesday, Aug. 14, 2024. She was 94. Peter Marshall, the actor and singer turned game show host who played straight man to the stars for 16 years on “The Hollywood Squares,” died. Thursday, Aug. 15, 2024 He was 98. Alain Delon, the internationally acclaimed French actor who embodied both the bad guy and the policeman and made hearts throb around the world, died Sunday, Aug. 18, 2024. He was 88. Phil Donahue, whose pioneering daytime talk show launched an indelible television genre that brought success to Oprah Winfrey, Montel Williams, Ellen DeGeneres and many others, died Sunday, Aug. 18, 2024, after a long illness. He was 88. Al Attles, a Hall of Famer who coached the 1975 NBA champion Warriors and spent more than six decades with the organization as a player, general manager and most recently team ambassador, died Tuesday, Aug. 20, 2024. He was 87. John Amos, who starred as the family patriarch on the hit 1970s sitcom “Good Times” and earned an Emmy nomination for his role in the seminal 1977 miniseries “Roots,” died Wednesday, Aug. 21, 2024. He was 84. James Darren, a teen idol who helped ignite the 1960s surfing craze as a charismatic beach boy paired off with Sandra Dee in the hit film “Gidget,” died Monday, Sept. 2, 2024. He was 88. James Earl Jones, who overcame racial prejudice and a severe stutter to become a celebrated icon of stage and screen has died. He was 93. His agent, Barry McPherson, confirmed Jones died Sept. 9 at home. Jones was a pioneering actor who eventually lent his deep, commanding voice to CNN, “The Lion King” and Darth Vader. Working deep into his 80s, he won two Emmys, a Golden Globe, two Tony Awards, a Grammy, the National Medal of Arts, the Kennedy Center Honors and was given an honorary Oscar and a special Tony for lifetime achievement. In 2022, a Broadway theater was renamed in his honor. Frankie Beverly, who with his band Maze inspired generations of fans with his smooth, soulful voice and lasting anthems including “Before I Let Go,” has died. He was 77. His family said in a post on the band’s website and social media accounts that Beverly died Sept. 10. In the post, which asked for privacy, the family said “he lived his life with a pure soul, as one would say, and for us, no one did it better.” The post did not say his cause of death or where he died. Beverly, whose songs include “Joy and Pain,” “Love is the Key,” and “Southern Girl,” finished his farewell “I Wanna Thank You Tour” in his hometown of Philadelphia in July. Joe Schmidt, the Hall of Fame linebacker who helped the Detroit Lions win NFL championships in 1953 and 1957 and later coached the team, has died. He was 92. The Lions said family informed the team Schmidt died Sept. 11. A cause of death was not provided. One of pro football’s first great middle linebackers, Schmidt played his entire NFL career with the Lions from 1953-65. An eight-time All-Pro, he was enshrined into the Pro Football Hall of Fame in 1973 and the college football version in 2000. Born in Pittsburgh, Schmidt played college football in his hometown at Pitt. Chad McQueen, an actor known for his performances in the “Karate Kid” movies and the son of the late actor and racer Steve McQueen, died Sep. 11. His lawyer confirmed his death at age 63. McQueen's family shared a statement on social media saying he lived a life “filled with love and dedication.” McQueen was a professional race car driver, like his father, and competed in the famed 24 Hours of Le Mans and the 24 Hours of Daytona races. He is survived by his wife Jeanie and three children, Chase, Madison and Steven, who is an actor best known for “The Vampire Diaries.” Tito Jackson, one of the brothers who made up the beloved pop group the Jackson 5, died at age 70 on Sept. 15. Jackson was the third of nine children, including global superstars Michael and Janet. The Jackson 5 included brothers Jackie, Tito, Jermaine, Marlon and Michael. They signed with Berry Gordy’s Motown empire in the 1960s. The group was inducted into the Rock & Roll Hall of Fame in 1997 and produced several No. 1 hits in the 1970s, including “ABC,” “I Want You Back” and “I’ll Be There.” John David “JD” Souther has died. He was a prolific songwriter and musician whose collaborations with the Eagles and Linda Ronstadt helped shape the country-rock sound that took root in Southern California in the 1970s. Souther joined in on some of the Eagles’ biggest hits, such as “Best of My Love,” “New Kid in Town,” and “Heartache Tonight." The Songwriters Hall of Fame inductee also collaborated with James Taylor, Bob Seger, Bonnie Raitt and many more. His biggest hit as a solo artist was “You’re Only Lonely.” He was about to tour with Karla Bonoff. Souther died Sept. 17 at his home in New Mexico, at 78. In this photo, JD Souther and Alison Krauss attend the Songwriters Hall of Fame 44th annual induction and awards gala on Thursday, June 13, 2013 in New York. Sen. Dan Evans stands with his three sons, from left, Mark, Bruce and Dan Jr., after he won the election for Washington's senate seat in Seattle, Nov. 8, 1983. Evans, a former Washington state governor and a U.S. Senator, died Sept. 20. The popular Republican was 98. He served as governor from 1965 to 1977, and he was the keynote speaker at the 1968 National Republican Convention. In 1983, Evans was appointed to served out the term of Democratic Sen. Henry “Scoop” Jackson after he died in office. Evans opted not to stand for election in 1988, citing the “tediousness" of the Senate. He later served as a regent at the University of Washington, where the Daniel J. Evans School of Public Policy and Governance bears his name. Eugene “Mercury” Morris, who starred for the unbeaten 1972 Miami Dolphins as part of a star-studded backfield and helped the team win two Super Bowl titles, died Sept. 21. He was 77. The team on Sunday confirmed the death of Morris, a three-time Pro Bowl selection. In a statement, his family said his “talent and passion left an indelible mark on the sport.” Morris was the starting halfback and one of three go-to runners that Dolphins coach Don Shula utilized in Miami’s back-to-back title seasons of 1972 and 1973, alongside Pro Football Hall of Famer Larry Csonka and Jim Kiick. Morris led the Dolphins in rushing touchdowns in both of those seasons. John Ashton, the veteran character actor who memorably played the gruff but lovable police detective John Taggart in the “Beverly Hills Cop” films, died Thursday, Sept. 26, 2024. He was 76. Maggie Smith, who won an Oscar for 1969 film “The Prime of Miss Jean Brodie” and won new fans in the 21st century as the dowager Countess of Grantham in “Downton Abbey” and Professor Minerva McGonagall in the Harry Potter films, died Sept. 27 at 89. Smith's publicist announced the news Friday. She was frequently rated the preeminent British female performer of a generation that included Vanessa Redgrave and Judi Dench. “Jean Brodie” brought her the Academy Award for best actress in 1969. Smith added a supporting actress Oscar for “California Suite” in 1978. Kris Kristofferson, a Rhodes scholar with a deft writing style and rough charisma who became a country music superstar and an A-list Hollywood actor, died Saturday, Sept. 28, 2024. He was 88. Drake Hogestyn, the “Days of Our Lives” star who appeared on the show for 38 years, died Saturday, Sept. 28, 2024. He was 70. Ron Ely, the tall, musclebound actor who played the title character in the 1960s NBC series “Tarzan,” died Sunday, Sept. 29, 2024, at age 86. Dikembe Mutombo, a Basketball Hall of Famer who was one of the best defensive players in NBA history and a longtime global ambassador for the game, died Monday, Sept. 30, 2024, from brain cancer, the league announced. He was 58. Frank Fritz, left, part of a two-man team who drove around the U.S. looking for antiques and collectibles to buy and resell on the reality show “American Pickers,” died Monday, Sept. 30, 2024. He was 60. He's shown here with co-host Mike Wolfe at the A+E Networks 2015 Upfront in New York on April 30, 2015. Pete Rose, baseball’s career hits leader and fallen idol who undermined his historic achievements and Hall of Fame dreams by gambling on the game he loved and once embodied, died Monday, Sept. 30, 2024. He was 83. Cissy Houston, the mother of Whitney Houston and a two-time Grammy winner who performed alongside superstar musicians like Elvis Presley and Aretha Franklin, died Monday, Oct. 7, 2024, in her New Jersey home. She was 91. Ethel Kennedy, the wife of Sen. Robert F. Kennedy, who raised their 11 children after he was assassinated and remained dedicated to social causes and the family’s legacy for decades thereafter, died on Thursday, Oct. 10, 2024, her family said. She was 96. Former One Direction singer Liam Payne, 31, whose chart-topping British boy band generated a global following of swooning fans, was found dead Wednesday, Oct. 16, 2024, after falling from a hotel balcony in Buenos Aires, local officials said. He was 31. Mitzi Gaynor, among the last survivors of the so-called golden age of the Hollywood musical, died of natural causes in Los Angeles on Thursday, Oct. 17, 2024. She was 93. Fernando Valenzuela, the Mexican-born phenom for the Los Angeles Dodgers who inspired “Fernandomania” while winning the NL Cy Young Award and Rookie of the Year in 1981, died Tuesday, Oct. 22, 2024. He was 63. Jack Jones, a Grammy-winning crooner known for “The Love Boat” television show theme song, died, Wednesday, Oct. 23, 2024. He was 86. Phil Lesh, a founding member of the Grateful Dead, died Friday, Oct. 25, 2024, at age 84. Teri Garr, the quirky comedy actor who rose from background dancer in Elvis Presley movies to co-star of such favorites as "Young Frankenstein" and "Tootsie," died Tuesday, Oct 29, 2024. She was 79. Quincy Jones, the multitalented music titan whose vast legacy ranged from producing Michael Jackson’s historic “Thriller” album to writing prize-winning film and television scores and collaborating with Frank Sinatra, Ray Charles and hundreds of other recording artists, died Sunday, Nov 3, 2024. He was 91 Bobby Allison, founder of racing’s “Alabama Gang” and a NASCAR Hall of Famer, died Saturday, Nov. 9, 2024. He was 86. Song Jae-lim, a South Korean actor known for his roles in K-dramas “Moon Embracing the Sun” and “Queen Woo,” was found dead at his home in capital Seoul, Tuesday, Nov. 12, 2024. He was 39. British actor Timothy West, who played the classic Shakespeare roles of King Lear and Macbeth and who in recent years along with his wife, Prunella Scales, enchanted millions of people with their boating exploits on Britain's waterways, died Tuesday, Nov 12, 2024. He was 90. Bela Karolyi, the charismatic if polarizing gymnastics coach who turned young women into champions and the United States into an international power in the sport, died Friday, Nov. 15, 2024. He was 82. Arthur Frommer, whose "Europe on 5 Dollars a Day" guidebooks revolutionized leisure travel by convincing average Americans to take budget vacations abroad, died Monday, Nov. 18, 2024. He was 95. Former Chicago Bulls forward Bob Love, a three-time All-Star who spent 11 years in the NBA, died Monday, Nov. 18, 2024. He was 81. Chuck Woolery, the affable, smooth-talking game show host of “Wheel of Fortune,” “Love Connection” and “Scrabble” who later became a right-wing podcaster, skewering liberals and accusing the government of lying about COVID-19, died Saturday, Nov. 23, 2024. He was 83. Barbara Taylor Bradford, a British journalist who became a publishing sensation in her 40s with the saga "A Woman of Substance" and wrote more than a dozen other novels that sold tens of millions of copies, died Sunday, Nov. 24, 2024. She was 91. Hall of Famer Rickey Henderson, the brash speedster who shattered stolen base records and redefined baseball's leadoff position, died Friday, Dec. 20, 2024. He was 65. Greg Gumbel, left, watches as then-Connecticut head coach Jim Calhoun talks to Butler head coach Brad Stevens, right, prior to taping a television interview April 3, 2011, for that year's men's NCAA Final Four college basketball championship game in Houston. Gumbel's family announced Dec. 27 that the longtime CBS sportscaster died from cancer at the age of 78. Sign up to get the most recent local obituaries delivered to your inbox.76ers' star Paul George sidelined the next 2 games with bone bruise in left knee