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Tax Liability Grantor Trusts Internal Revenue Service

Strafford

[Webinar] New IRS Guidance on Basis Adjustments for Irrevocable Grantor Trusts: Key Issues for U.S. and Non-U.S. Persons - June...

Strafford on

This CLE/CPE webinar will provide estate planners insight on recently issued IRS guidance regarding basis adjustments for irrevocable grantor trusts. The panelist will discuss key items and challenges stemming from Revenue...more

Cadwalader, Wickersham & Taft LLP

Exchange Trust Certificates in REMIC Transactions Qualify as Stripped Bonds or Coupons

On November 24, 2023, the IRS released PLR 202347001, ruling that certificates issued from an “exchange trust” qualify as stripped bonds or stripped coupons within the meaning of Code Section 1286. The taxpayer in the...more

Freeman Law

The IRS and Abusive Trust Arrangements: Non-Grantor Trusts

Freeman Law on

Under federal tax law, there are significant differences between grantor and non-grantor trusts. Grantor trusts are treated as disregarded entities.  In layman’s terms, this means that the grantor (i.e., the creator or the...more

Freeman Law

Section 643(b) and Trusts

Freeman Law on

Recently, there seems to be some confusion regarding section 643(b) of the Internal Revenue Code of 1986, as amended (the “Code”), and its application to trusts. Indeed, that provision—particularly to those not well-versed in...more

Freeman Law

Why You Should Hire a Tax Professional to Review Your Trust

Freeman Law on

Trusts come in many variations, rendering them often difficult for non-attorneys to follow and comprehend.  Indeed, this variation can often be seen in the nomenclature used for trust arrangements, which includes terms such...more

Rivkin Radler LLP

Planning for the Interest Charge on Installment Sales: Decanting a Grantor Trust?

Rivkin Radler LLP on

I recently encountered an interesting situation in which someone suggested that a grantor trust be decanted into a non-grantor trust before the end of the taxable year. The reason? To avoid the special interest charge that...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposals for Trusts, Estates, and Retirement Accounts

Bowditch & Dewey on

In this second blog post on the House Ways and Means Tax proposals, we address the proposed changes that will affect the taxation of trusts, estates, and retirement plans. As we discussed, on September 13, 2021, the...more

Proskauer Rose LLP

Wealth Management Update - June 2013

Proskauer Rose LLP on

The June § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.2%, which is a slight decrease from April's rate of 1.4% but remains the same as May's rate of 1.2%. The applicable federal...more

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