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Income Taxes › Nongrantor Trusts

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Gray Reed

IRS Takes Warning Shot at Section 643(b) Trust Arrangements

Gray Reed on

For some time, promoters have shopped around an arrangement known as a “section 643(b) trust,” known alternatively as a “non-grantor, irrevocable, complex, discretionary, spendthrift trust.”  On August 9, 2023, IRS Chief...more

Snell & Wilmer

New California Law Attacks NINGs and DINGs

Snell & Wilmer on

On July 10, 2023, California Governor Gavin Newsom signed into law S.B. 131, which included a provision targeting the California state income tax treatment of incomplete gift non-grantor trusts ("INGs"). Under the prior law,...more

Freeman Law

The IRS and Abusive Trust Arrangements: Non-Grantor Trusts

Freeman Law on

Under federal tax law, there are significant differences between grantor and non-grantor trusts. Grantor trusts are treated as disregarded entities.  In layman’s terms, this means that the grantor (i.e., the creator or the...more

Venable LLP

Incomplete Gift Non-Grantor Trusts Created by California Residents May Be Subject to California State Income Tax Beginning in 2023

Venable LLP on

Under California Governor Gavin Newsom's proposed 2023-2024 state budget, released on January 10, 2023, the income of an incomplete gift non-grantor trust (ING Trust) may now be subject to California income tax, effective on...more

McDermott Will & Emery

[Webinar] US Taxation of Grantor/Non-Grantor Trusts - June 24th, 3:00 pm BST

McDermott Will & Emery on

Astrid Owen leads this interactive webinar to discuss the US taxation of US beneficiaries and US settlors of non-US trusts. The benefit of using non-US grantor trusts established by a non-US person for US beneficiaries...more

Adler Pollock & Sheehan P.C.

Insight on Estate Planning - Year End 2019: IDGT: This trust is supposed to “fail”

Adler Pollock & Sheehan P.C. on

Trusts come in all shapes and sizes. However, from an income tax perspective, there are basically two types: grantor trusts and nongrantor trusts. An intentionally defective grantor trust (IDGT) has the best attributes of...more

Adler Pollock & Sheehan P.C.

Insight on Estate Planning - Year End 2019

Adler Pollock & Sheehan P.C. on

We are pleased to present the Year End 2019 issue of Insight on Estate Planning We encourage you to read through it for ideas about ways you can minimize taxes on your estate and maximize its value for your loved ones. In...more

Adler Pollock & Sheehan P.C.

Trusts and taxes - Understanding how one affects the other can benefit your estate plan

Adler Pollock & Sheehan P.C. on

Trusts typically are a main component of an estate plan. But many may not know how higher taxes can impact a trust’s overall effectiveness. This article explains how the current tax environment affects trust planning....more

Proskauer Rose LLP

Wealth Management Update - October 2015

Proskauer Rose LLP on

October Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The October § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more

Adler Pollock & Sheehan P.C.

Avoid state income taxes with an incomplete nongrantor trust

Adler Pollock & Sheehan P.C. on

Now that the federal gift and estate tax exemption has reached an inflation-adjusted $5.43 million, many people are shifting their estate planning focus to income tax reduction. One potentially attractive strategy for...more

Adler Pollock & Sheehan P.C.

Insight on Estate Planning - August/September 2013: Estate Planning Pitfall - You haven’t reviewed your trusts this year

Adler Pollock & Sheehan P.C. on

If an estate plan includes one or more trusts, it’s a good idea to review them in light of recent tax law changes. Higher income taxes — on individuals as well as trusts — may make it advisable to rethink the way the trusts...more

Gerald Nowotny - Law Office of Gerald R....

Dodgeball - The Tax Version

Gerald Nowotny - Law Office of Gerald R.... on

Since the passage of The American Taxpayer Relief Act of 2012 and the submission of the President's federal budget proposal for 2014, it is clear that high net worth and high income taxpayers continue to be under attack....more

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