generation-skipping trust

• Generation skipping trusts

• Severance of a Trust for Generation-Skipping Transfer (GST) Tax Purposes

• FR, July 31, 2008
• Rules
• Internal Revenue Service

• Estate and gift taxes: Generation-skipping transfer tax purposes; qualified severance of trust,

• FR, August 02, 2007
• Rules
• Internal Revenue Service

• T.D. 9348

D. 9348, under Section 2642, provides guidance regarding the qualified severance of a trust for generation-skipping transfer tax purposes under Section 2642(a)(3).

• United States. Internal Revenue Bulletin
• August 21, 2009

• Estate and gift taxes: Generation-skipping transfer tax purposes; severance of trust,

• FR, August 02, 2007
• Proposed rules
• Internal Revenue Service

• Lorraine G. Grace, Individually and as Executrix of the Estate of Oliver R. Grace, Gerald I. White, Trustee U/W Morgan H. Grace, for the Marital Deduction Trust, Gerald I. White, Trustee U/W Morgan H. Grace for the Non-Marital Deduction Trust and Gerald I. White, Trustee U/W Morgan H. Grace for the Generation Skipping Trust and Gerald I. White, Trustee of the John E. Grace Trust, Individually and as Stockholders of Briggs Leasing Corp., Suing on Behalf of Themselves and for the Benefit of Said Corporation and for the Class of all Other Stockholders of Said Corporation Similarly Situated, Plaintiffs-Appellants, v. Bank Leumi Trust Company of New York, David Mack, the Estate of Leo v. Berger, Apex Marine Corp., Harvey Schwartz, Phyllis Sepe and Sigmund Kassap, Trustee of the Leo v. Berger Grantor Trust No. 1 as Personal Representative of the Estate of Leo v. Berger, Non-Party Movants-Defendants-Appellees, Robert Rosenstock, Robert Genser, Edward Rosenstock, Briggs Leasing Corporation and Briggs Acquisition ..., 443 F.3d 180 (2nd Cir. 2006)

• Federal Circuits

• Use of a dynasty trust in estate planning.

The use of a dynasty, or generation-skipping, trust may provide taxpayers with substantial assets the opportunity to delay high estate taxes as long as possible. Taxpayers can transfer up to $1 million each to a grandchild without triggering the generation-skipping tax. To allow maximum flexibility and the greatest reach in future generations, a trust should be formed that can respond to changes such as financial need or children born after trust formation.

• The Tax Adviser
• Vol. 25 Nbr. 3, March 1994

• Notice 2008-63

sets and requests comments on a proposed revenue ruling concerning the income, estate, gift, and generation-skipping transfer tax consequences in situations in which family members create a private trust company to serve as the trustee of trusts having family members as grantors and beneficiaries.

• United States. Internal Revenue Bulletin
• August 27, 2009

• Get Ahead of the Curve: Estate Tax Resolution Triggers Renewed Demand for Estate Planning

Escalating Death Benefit In recent years, the life insurance industry also has introduced an interesting new tool for estate planning - an adjustable term insurance rider that is typically attached to a universal life insurance policy. Securing the Grandkids A boomer client looking to further shelter assets from taxation after his or her death may be a candidate for an irrevocable life insurance trust, that can be used to leverage generation-skipping transfer (GST) tax exemption ($2 million in 2008; $3.5 million in 2009).

• Life Insurance Selling
• Vol. 83 Nbr. 1, January 2008

• Reg-153841-02

Proposed regulations provide guidance for making the election under Section 2632(c) to not have the deemed allocation of unused generation-skipping transfer (GST) tax exemption apply with regard to certain transfers to a GST trust. The regulations also provide guidance for making the election to treat a trust as a GST trust.

• United States. Internal Revenue Bulletin
• July 31, 2009

• Estate Must Pay Generation-Skipping Transfer Tax, Rules 6th Circuit

A decedent's estate could not claim an exemption from the generation-skipping transfer tax for transfers from an estate trust to the settlor's grandnieces and grandnephews, the 6th Circuit has ruled in affirming judgment. The generation-skipping transfer (GST) tax was enacted in 1976. The tax was intended to remove the estate planning tool of escaping taxation by skipping a generation in an estate transfer.

• Lawyers USA
• April 13, 2010