Once Removed Episode 18: The Reciprocal Trust Doctrine
The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more
Taxpayers have long utilized trust arrangements for the transfer of wealth to beneficiaries or for the protection of assets from creditors. Generally, there is nothing nefarious about these types of arrangements. Rather,...more
February Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The February § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more
In this Issue: - March Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra Family Loans and Split Interest Charitable Trust - Estate of Giovacchini v. Commissioner, T.C. Memo 2013-27 - Estate of...more