-
Articles & Seminar Materials
- June 5 NYS Tax Litigation Seminar: Completion Certificate June 2, 2025
- June 5 NYS Tax Litigation Seminar — Outline May 31, 2025
- June 5 Tax Litigation Seminar — Supplementary Materials May 14, 2025
- June 5 CPE Seminar: NYS Tax Litigation — Practice & Procedure April 28, 2025
- March 13 CPE Seminar: Supplementary Materials March 4, 2025
- Income Taxation of New York Trusts & 2025 Planning Strategies March 4, 2025
- Webinar Recording of 1031 Final Regulations Seminar January 16, 2025
-
Natural Language Search
Search by Category
Most Popular
- Letters Testamentary
- Welcome
- Taxpayer Bill of Rights 2 (May 1996)
- DOMESTIC ASSET PROTECTION TRUSTS
- IRS Statutes of Limitations
- The Decedent's Final Income Tax Return
- Conciliation Conference
- Installment Sale Reporting of Deferred Exchange Boot
- Defeating The Right of Election in EPTL § 5-1.1-A
- Article 78 Appeals to Appellate Division, Third Department
Tag Archives: trustees
INSTALLMENT SALES OF ASSETS TO “DEFECTIVE” GRANTOR TRUSTS
Installment sales of assets to grantor trusts indirectly exploit income tax provisions enacted to prevent income shifting at a time when trust income tax rates were much lower than individual tax rates. Specifically, the technique capitalizes on different definitions of “transfer” for transfer tax and grantor trust income tax purposes. The resulting trusts are termed “defective” because the different definitions of “transfer” result in a serendipitous divergence in income and transfer tax treatment when assets are sold by the grantor to his own grantor trust. Continue reading