qualified terminable interest property trusts

• Qualified terminable interest property trusts

• Recent developments in QPRTs and QTIPs.

Qualified personal residence and qualified terminable interest property trusts

• The Tax Adviser
• Vol. 31 Nbr. 6, June 2000

• Rev. Proc. 2004-47

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.

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

• QTIPing an IRA.

Qualified terminable interest property trusts

• The Tax Adviser
• Vol. 31 Nbr. 6, June 2000

• 26 CFR 20.2056(b)-7 - Election with respect to life estate for surviving spouse.

... dying after December 31, 1981, for qualified terminable interest property as defined in paragra...(ii) Division of trusts(A) In general. A trust may be divided into separat...

• Code of Federal Regulations - Title 26: Internal Revenue

• What is an irrevocable trust?

.... There are two types of trusts commonly found in Wills. The first is a Minor's Tr...For example, there are Qualified Terminable Interest Property (QTIP) trusts, marita...

• Wills & Estates
• Questions & Answers

• Postmortem disclaimer strategies.

Disclaimer under IRC section 2518 can be a particularly valuable planning tool after death to cure deficiencies or mistakes in estate planning. A bequest that would be taxable because it exceeds the unified credit could be disclaimed to place the funds back under the marital deduction. Some portion of funds left to the spouse could be disclaimed to take advantage of unused unified credits or generation-skipping transfer tax exemptions. Defects in qualified terminable interest property trusts and other trusts can be cured by the disclaimer of an otherwise disqualifying transfer.

• The Tax Adviser
• Vol. 26 Nbr. 7, July 1995

• Significant recent developments in estate planning.

Part 3 Tax cases, letter rulings, revenue rulings and changes in tax law in 1993-1994 focused on estate planning issues including special valuation, income tax on fiduciaries and generation-skipping transfers (GSTs). GST issues included exemptions, GST trusts and qualified terminable interest property elections. Income in respect of decedents, debt relief and qualified subchapter S trusts were addressed in rulings. The IRS also considered grantor retained annuity trusts, qualified personal residence trusts and valuation of decedent's estates and gifts.

• The Tax Adviser
• Vol. 25 Nbr. 12, December 1994

• Using a QTIP trust to extend the life of an IRA.

Qualified terminable interest property (QTIP) trusts may be used as beneficiaries for individual retirement accounts (IRAs). As an estate tax planning tool, it has the advantage of being passed to the surviving spouse from the decedent, thereby avoiding taxes. Furthermore, QTIP trusts are named directly to the recipient. However, the Internal Revenue Service ruled that withdrawals from the IRA's balance and income must be made by the trust itself.

• The National Public Accountant
• Vol. 41 Nbr. 4, April 1996

• Property Rights of a Disinherited Spouse

When reviewing an estate, a tax advisor must determine what assets will pass to an individual's surviving spouse upon the death to capitalize on the marital deduction. Determining the marital deduction may be important because, upon death, the value of any interest in property that passes to the surviving spouse will be deducted from the decedent's gross estate. Estate tax advisors should be informed about the property rights that a disinherited spouse may possess with respect to property owned by a decedent at the time of death, as well as other property the deceased spouse may have transferred during the spouse's lifetime. A spouse who is legally married to the deceased spouse at the time of death cannot be totally disinherited, even if the surviving spouse was omitted either intentio...

...Certain trusts and nuptial agreements can be used to protect a in... prior to August 31, 1994, to contain qualified terminable interest property (Q-TIP) trusts, which...

• CPA Journal, The
• Vol. 78 Nbr. 5, May 2008

• Significant recent developments in estate planning.

Part 2 A survey of 1993-94 cases and revenue rulings focuses on changes in the marital deduction, valuation and special use valuation laws. Decisions involving the estate tax marital deduction focused on qualified terminable interest property elections, restrictions on property interests and assets held in certain pools and trusts. Valuation rulings considered valuation methods, discounts in valuation, safe harbors and the effect of partnership agreements on partnership interest valuation. Special use valuation cases addressed qualified use, disclaimers and IRC section 2032A recapture.

• The Tax Adviser
• Vol. 25 Nbr. 11, November 1994