grantor

• Grantor retained annuity trusts

• Grantor trusts

• Grantor retained unitrusts

• Creative ways of achieving grantor trust status.

Sometimes a C corporation considering S corporation status has a trust as a shareholder. If the trust was not originally drafted with the intent of be...

• The Tax Adviser
• Vol. 40 Nbr. 9, September 2009

• Intentionally defective grantor trusts.

Estate tax planners have long employed intentionally defective grantor trusts to freeze the value of an asset for estate tax purposes while transferri...

• Journal of Accountancy
• Vol. 206 Nbr. 5, November 2008

• 26 CFR 1.677(a)-1 - Income for benefit of grantor; general rule.

• Code of Federal Regulations - Title 26: Internal Revenue

• PLR 201039010 - The Latest Beneficiary Grantor Trust Ruling.

Originally published in the BNA Tax Management Estates, Gifts & Trusts Journal A beneficiary grantor trust -- an irrevocable trust treated as owned ...

• Mondaq Business Briefing
• Nbr. 2011, January 2011

• The case for an intentionally defective grantor trust.

When two sets of tax laws use different standards to measure the outcome of a single transaction, some advisers call the result a loophole. Others cal...

• The Tax Adviser
• Vol. 39 Nbr. 11, November 2008

• Leading Grantor Trust Experts Say 'Know the Income Tax Consequences When Changing the Status of a Trust!'

ARLINGTON, Va., April 13 /PRNewswire/ -- Join the nation's leading Grantor Trust experts as they discuss the use of installment sales to grantor trusts, installment sales to non-grantor trusts, and private annuity sales to grantor trusts. On April 27, Jonathan Blattmachr, Jerry Hesch, Mitchell Gans and Elliott Manning will deliver a new BNA Tax & Accounting webinar - Grantor Trust Liabilities: The Income Tax Consequences when Changing the Status of a Trust - identifying the income tax issues that arise when liabilities, including seller-provided financing are part of a transaction and the fundamental income tax principles used to resolve these issues. (Logo: http://www.newscom.com/cgi-bin/prnh/20090114/DC59060LOGO- b)

• U.S. Newswire
• April 13, 2010

• in Re Baltimore Emergency Services Ii, Corporation, Debtor. Steven M. Scott, Appellant, v. National Century Financial Enterprises, Incorporated; Pappg Grantor Trust, Creditors-Appellees., 432 F.3d 557 (4th Cir. 2005)

ARGUED: Mack Sperling, Brooks, Pierce, McLendon, Humphrey & Leonard, Greensboro, North Carolina, for Appellant. Richard Marc Goldberg, Shapiro, Sher, ...

• Federal Circuits

• PLR 201039010 - The Latest Beneficiary Grantor Trust Ruling

Originally published in the BNA Tax Management Estates, Gifts & Trusts Journal A beneficiary grantor trust — an irrevocable trust treated as owned ...

• Mondaq Business Briefing
• United States Law Articles in English

• Estate & Personal Financial Planning

The precipitous drop in the real estate and securities markets has certainly been painful for many, yet there is a silver lining. Depressed asset values, low interest rates, and the likelihood of continuing federal estate taxes make certain federal estate tax planning strategies extremely attractive. Two such strategies are transfers to grantor retained annuity trusts (GRATs) and sales to intentionally defective grantor trusts (IDGTs). Both are "estate freeze" techniques, with each permitting the transfer of an asset's future appreciation without significant use of federal estate and gift tax exemptions. The GRAT is a creature of IRC Section 2702, whereby a taxpayer may transfer assets to a GRAT in return for the right to receive annuity payments for a term years. Advantages of the IDGT...

• Pennsylvania CPA Journal
• Vol. 80 Nbr. 1, April 2009

• 36 CFR 251.17 - Grantor's right to occupy and use lands conveyed to the United States.

• Code of Federal Regulations - Title 36: Parks, Forests, and Public Property