Search by Category
Natural Language Search
Recent Articles & Treatises
- Table of Contents for May 18 Lecture Materials April 28, 2023
- Register for Thursday, May 18 Tax Seminar in Old Westbury [click card to register] April 12, 2023
- Subscribe to Tax News & Comment April 6, 2023
- Tax News & Comment — April 2023 March 31, 2023
- Tax News & Comment — June 2019 March 4, 2023
- 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
- Executor and Trustee Commissions Under NY EPTL
- Legal Basis for Seeking Abatement of New York State Tax Penalties
- Letters Testamentary
- Register Now for May 18 Breakfast Seminar in Old Westbury. 2.5 CPE Credits for CPAs in Tax. Still time to register! See Table of Contents below. Click card to register online.
- Distributable Net Income and Income in Respect of a Decedent
- Gain, Loss and Depreciation Issues in Like Kind Exchange
- New York's Revised Decanting Statute Under EPTL §10-6.6
- Rev. Rul. 85-13: Is There a Limit to Disregarding Disregarded Entities?
- Defeating The Right of Election in EPTL § 5-1.1-A
- Challenging The Account of a Fiduciary
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 Leave a comment
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 Leave a comment
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