grantor trust rules

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grantor trust income tax rules

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2.324 documents for grantor trust rules

- Income taxes: Trusts with foreign grantors; application of grantor trust rules,
- FR, August 10, 1999
- Rules
- Internal Revenue Service
- Proposed section 671 regulations relating to application of grantor trust rules to nonexempt employee trusts.
Amendments should be made to the proposed IRC section 671 regulations on the use of grantor trust rules in conjunction with nonexempt employee trusts, including foreign employees' retirement funds. The proposed surplus assets calculation method is burdensome and generally accepted accounting principles should be used instead. The Form 5471 filing requirement should be eliminated and the reasonable funding method exception should be broadened. Also, the provision on the definition of "foreign employees' trust" should be clarified.
- Tax Executive
- Vol. 49 Nbr. 2, March 1997
- U.S. House Passes Legislation That Would Modify Grantor Retained Annuity Trust (GRAT) Rules
On March 24, 2010, the U.S. House of Representatives passed H.R. 4849—known as the Small Business and Infrastructure Jobs Tax Act. The bill was sponso...
- Mondaq Business Briefing
- United States Law Articles in English

- U.S. House Passes Legislation That Would Modify Grantor Retained Annuity Trust (GRAT) Rules.
On March 24, 2010, the U.S. House of Representatives passed H.R. 4849--known as the Small Business and Infrastructure Jobs Tax Act. The bill was spons...
- Mondaq Business Briefing
- Nbr. 2010, January 2010
- Give It Away, Freeze Asset Values, and Cut Tax Tomorrow
One way to reduce taxes tomorrow is to 'freeze' assets today. In this article, the author explains two ways to freeze assets that have interested his key clients. In addition, these techniques allow for the sale of large amounts of needed additional life insurance. Effective strategies to freeze assets include the gifting or selling of assets to "grantor trusts." Both techniques freeze assets at today's values, but they take different forms and lead to different consequences. With a grantor-retained annuity trust (GRAT), clients can gift and transfer income-producing assets to an irrevocable trust, receiving a stream of income from the annuity for the term of the trust. If clients and their advisors are willing to be more aggressive, they might consider a tactic not specifically spelled...

... the powers delineated in the grantor trust rules of the Internal Revenue Code. In the past, the fac...
- Life Insurance Selling
- Vol. 83 Nbr. 9, September 2008
- Holywell Corp. v. Smith, 503 U.S. 47 (1992)
... placement of the debtors' property into a trust and appointment of a trustee to liquidate all of t... pay the trust's taxes under the Code's "grantor trust" rules is rejected. In re Sonner, 53 B. R. 8...
- U.S. Supreme Court
- 26 CFR 1.672(f)-1 - Foreign persons not treated as owners.
... 1 of the Internal Revenue Code (the grantor trust rules) shall apply only to the extent such a...
- Code of Federal Regulations - Title 26: Internal Revenue
- New questions spring from the application of ESBT provisions.
Electing small business trust The 1997 electing small business trust (ESBT) provisions, which allow an S corporation to be owned by an ESBT, conflict with some existing state laws. Penn and Calif tax laws on S status, for example, do not conform with the revised federal provisions. Other unresolved issues include trust distribution treatment when an ESBT holds other assets and the coordination between grantor trust and ESBT rules. The rules do provide more flexible estate planning options for S corporation owners.
- The Tax Adviser
- Vol. 28 Nbr. 8, August 1997
- New Proposals May Limit Estate Planning Opportunities.
... that, if enacted, would make many common trust arrangements far less effective. . New Proposal: EElimination of Transfer Tax Benefits of Grantor Trusts . A common trust planning technique is to e... tax payable as a result of the proposed rules would be payable from the trust, and not by the gr...
- Mondaq Business Briefing
- Nbr. 2012, January 2012
- Creative ways of achieving grantor trust status.
... knows the intricacies of the grantor trust rules of Secs. 671-677. . This item has three sections. ...
- The Tax Adviser
- Vol. 40 Nbr. 9, September 2009