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Recent Articles & Treatises
- Registration now open for September 17, 2019 CPE Seminar, “IRC Sec. 199A: Wasn’t the Code to be Simplified?” August 26, 2019
- A Journey Through IRC Section 199A: Wasn’t the Code to be Simplified? July 25, 2019
- Tax News & Comment — August 2019 July 25, 2019
- Tax News & Comment – April 2017 March 13, 2017
- Tax News & Comment — May 2016 May 14, 2016
- FROM WASHINGTON & ALBANY — Current Election Probabilities; Tax Plans of Trump and Clinton May 13, 2016
- FROM FEDERAL AND NYS COURTS: Recent Developments & 2015 Decisions of Note May 13, 2016
- IRS & NYS DTF MATTERS: Recent Developments & 2015 Regs. & Rulings of Note May 13, 2016
- Creating and Maintaining Flexibility in Wills and Trusts May 13, 2016
- Escaping the Quandary Posed by Unreported Foreign Accounts May 13, 2016
- Like Kind Exchanges Alive and Well: An Update May 13, 2016
Most Popular
- Executor and Trustee Commissions Under NY EPTL
- Living Wills
- Distributable Net Income and Income in Respect of a Decedent
- Depreciation Recapture
- September 17 CPE Breakfast Lecture in Old Westbury, New York -- "IRC Sec. 199A: Wasn't the Code to be Simplified?"
- Use of Disclaimers in Pre and Post-Mortem Estate Planning
- Gain, Loss, Basis & Debt Issues in Like-Kind Exchanges
- Defeating The Right of Election in EPTL § 5-1.1-A
- Taxation of Foreign Nongrantor Trusts: Throwback Rule
- REMOVING FEDERAL TAX LIENS
Tag Archives: grantor trusts
Rev. Rul. 85-13: Is There a Limit to Disregarding Disregarded Entities?
I. Introduction Although the federal estate tax is not extinct, with the combined marital exemption now north of $10 million, it is an endangered species. Recently, Governor Cuomo signaled his intent — likely to be affirmed by State Republicans — … Continue reading
Posted in Asset Sales to Grantor Trusts, Estate Planning
Tagged defective grantor trusts, disregarded entities, estate planning, federal estate tax exemption, grantor trusts, IRC section 675, irc section 675(4)(C), nongrantor trust, nys estate tax, Portability, qprts purchase residence, Revenue Ruling 85-13, sales to defective grantor trusts, sales to grantor trusts, substitution power
Taxation of Grantor Trusts
Posted in Delaware Asset Protection Trusts, Grantor Trust Treatise, Grantor Trusts, Grantor Trusts, News, Treatises, Trusts
Tagged administrative powers, adverse party, asset protection trusts, beneficial enjoyment, beneficial owner, compliance issues grantor trusts, Delaware Asset Protection Trust, estate planning, fiduciary accounting income, fiduciary income, grantor trusts, IRC 671, irc 672, irc 673, IRC 674, irc 675, irc 676, IRC 677, irc 678, mallinckrodt trusts, nevada asset protection trust, nonadverse party, nongrantor trusts, plr 200131002, power to control beneficial interest, reporting grantor trust income, substitution powers, table income of trust
Asset Sales to Grantor Trusts: Antidote to New Estate Tax?
PDF: Sales of Assets to Defective Grantor Trusts I. Introduction Asset sales to grantor trusts exploit income tax provisions enacted to prevent income shifting by capitalizing on different definitions of “transfer” for transfer and income tax purposes. The objective … Continue reading
