2055(e) did not apply, because the state court's decree replaced the split-interest
trust with direct cash payments to the charities.
Form over substance: district court denies split-interest charitable deduction
Isadore Sharp, founder, CEO and chairman of the Four Seasons hotel chain, attributes much of his organization's success in building
trust with employees and customers to communicating and practicing the Golden Rule.
Trust in your organization's future: building trust inside and out is a key part of the communicator's role as the corporate conscience
H creates an irrevocable
trust with W and his friend X as trustees to be the policy's applicants, owners and beneficiaries.
Alternatives to funding life insurance premiums
They funded the
trust with $15 million, which was invested in securities the income from which would be used to make the trust's required yearly charitable donations.
Charitable lead trust can't deduct prepaid amounts
The TPT can be designed as a domestic trust or as a foreign
trust with stronger asset-protection features, yet be treated as a domestic trust for Federal income tax reporting purposes.
Third-party trusts integrate estate and asset-protection planning
A
trust with a modest portfolio intended to fund education could have a relatively simple plan, while one planning for extensive real estate holdings that are intended to provide multiple generations of beneficiaries with income may have a much more complicated plan.
Advising trustees: Lessons from the revised Uniform Principal and Income Act
* Funding the
trust with sufficient cash to pay the premiums on an insurance Policy on the grantor's life.
A primer on trusts
In Scott, the individual trustees of a testamentary
trust with $25 million in assets paid investment advisory, custodian, trustees' and return preparation fees in 1996 and 1997.
Trusts, investment advisory fees and the 2% floor
Example 4: D is a grantor of a revocable
trust with $100,000 in assets.
Medicaid eligibility rules
This article examines important issues in funding a QTIP
trust with an IRA, including a recent IRS pronouncement that liberalized some of the rules.
Using IRAs to fund QTIP trusts
The taxpayer creates an irrevocable
trust with beneficiaries that ultimately would receive his assets on death.
Planning options with intentionally defective irrevocable trusts
If the grantor were to sell a valuable asset on credit to the
trust with no net worth, the IRS might consider the transaction a sham.
GISTs
Notwithstanding this and other unfavorable rulings, however, the Crummey battle appears one the taxpayer is likely to win in the long run, absent a legislative change.(21) In Holland,(22) the Tax Court again sided with the taxpayer in a case addressing a number of gift and estate tax issues, including transfers in
trust with Crummey powers.
Significant recent developments in estate planning
A
trust with a zero inclusion ratio is exempt from GST tax.
AICPA's legislative solution to the GST tax exemption allocation trap
This will be so even if each plan has the same benefit structure or plan document, or if all or part of the assets are invested in one
trust with separate accounting for each plan.
Planning with welfare benefit plans after the Prime Financial decisions: a case for caution for Sec. 419A(f)(6)