Tag: 678

Intentionally Defective Grantor Trusts – Have your cake and eat it, too

Estate and Gift Tax, Estate Planning, Income Tax, Revenue Rulings, Tax

Shortly before his passing, Benjamin Franklin uttered one of his more infamous quotes, “In this world, nothing is certain except death and taxes.” With the certainty of death implicitly comes another: everyone will transfer his or her wealth, whether in life or after death. How a person transfers wealth will affect how the other certainty,…
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Threading the Needle – The Utility and Structural Requirements of ING Trusts

Asset Protection, Business Transactions, Estate and Gift Tax, Estate Planning, Income Tax, State and Local Tax, Tax

Estate planners and tax practitioners have been utilizing incomplete non-grantor trusts, or “ING” trusts, with increased frequency. ING trusts can be utilized for a number of reasons, including, but not limited to, federal income tax planning,[1] asset protection, planning for qualified small business stock benefits, income shifting through distributions to descendants, and others. While this…
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