Maybe It Works, Maybe It Doesn't: Installment Sales to Grantor Trusts
- Gain Is Realized at Death. Cantrell, Carol A. // Trusts & Estates;Feb2010, Vol. 149 Issue 2, p20
The author argues that the death of the grantor of an irrevocable grantor trust with an outstanding note balance is a part sale-part gift occurring on the last day of the grantor's taxable year. She mentions that the grantor realizes gain that constitutes income in respect of a decedent (IRD)....
- No Gain at Death. Gans, Mitchell M.; Blattmachr, Jonathan G. // Trusts & Estates;Feb2010, Vol. 149 Issue 2, p34
The authors argue that gain is not triggered by the grantor's death in the context of an installment sale and that the income in respect of a decedent (IRD) under the Internal Revenue Code Section 691 is not applicable. They argue that the no-gain-at-death rule is traceable to the U.S. Supreme...
- It's Not "Business As Usual" These Days. Lang, Patrick A. // National Underwriter / Life & Health Financial Services;2/15/2010, Vol. 114 Issue 4, p20
The article discusses the techniques that work in the current low interest rate and depressed asset value environment under the applicable federal rate and IRC Section 7520 rate in the U.S. It states that the techniques include outright gifts, intra-family loans, installment sales and...
- How to shelter your gifts. Hochberg, R. Mark // Financial World;2/26/96, Vol. 165 Issue 3, p102
Discusses the advantages of giving gifts through a grantor retained interest trust (GRIT). Allowing the individual to continue to receive income from the assets of the trust; Reduction of the value of the gift to the beneficiaries of the trust; Gift tax consequences of a GRIT.
- Grantor's powers to remove/appoint trustees. // Practical Accountant;Sep95, Vol. 28 Issue 9, p20
Reports on revenue rulings dealing with the grantor's power to remove and/or appoint trustees.
- Application of grantor trust rules to non-exempt employees' trusts. // Practical Accountant;Nov96, Vol. 29 Issue 11, p22
Reports on the issuance of proposed regulations (REG-209826-96) relating to the application of grantor trust rules to non-exempt employee's trust.
- THE DECREASING INTEREST RATE ENVIRONMENT. Gacinski, John A.; Lipoff, Lawrence M.; Schoenfeld, Susan R.; Landau, Jerome; Simon, Debra M.; Sonet, Richard H.; Brizard, Peter; Gordon, Ellen G.; Gold, Jeffrey S.; Salupsky, Harriet B. // CPA Journal;Aug2001, Vol. 71 Issue 8, p54
Focuses on the impact of the declining interest rates on the effectiveness of grantor retained annuity trusts (GRAT) in the United States. How a GRAT operates; Computation of the annuity based on the rate specified by Internal Revenue Code section 7520; Cost of implementing GRAT.
- Has the QPRT lost its perk? Caplan, Robert M. // Outlook;Winter97, Vol. 64 Issue 4, p46
Focuses on the Qualified Personal Residence Trust (QPRT) as an effective estate planning tool despite restrictions of the Proposed Regulations 25.2702-5 in the United States. Explanation of the QPRT; Advantage and disadvantage of the Proposed Regulations 25.2702-5 on QPRT; Circumstances...
- Tax Facts Concept: Grantor Trust Rules. Cady, Donald F. // National Underwriter / Life & Health Financial Services;12/11/2000, Vol. 104 Issue 50, p12
Provides information on grantor trust rules. Factors that would consider a trust to be a grantor trust; Advantages of the trust rules for taxpayers.