qualified terminable interest property
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The estate in Bonner received favorable treatment from the US Court of Appeals for the Fifth Circuit, but the Court's willingness to apply minority interest discounts in valuing estate property could be disadvantageous in other situations. The Court applied minority discounts to assets held by the decedent's qualified terminable interest property (QTIP) trust, despite the fact that balance of the property interests were held by the decedent outright. In the marital trust context, the application of minority discounts could reduce the marital deduction and the available unified credit.
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provides a simplified alternate procedure (in lieu of requesting a letter ruling) for certain executors of estates and trustees of trusts to request relief to make a late reverse qualified terminable interest property election under Section 2652.
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Qualified terminable interest property
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The federal estate tax recovery statute doesn't override the intent of a husband and wife that taxes be paid on a pro-rata basis from trusts created upon their deaths, the Washington Court of Appeals has ruled in affirming judgment.
Under 26 U.S.C. Sect. 2207A, a survivor's estate is entitled to recover federal estate taxes attributable to a Qualified Terminable Interest Property (QTIP) trust.
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Qualified personal residence and qualified terminable interest property trusts
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Qualified terminable interest property
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Qualified terminable interest property trusts