2055(e) did not apply, because the state court's decree replaced the split-interest
trust with direct cash payments to the charities.
Isadore Sharp, founder, CEO and chairman of the Four Seasons hotel chain, attributes much of his organization's success in building
trust with employees and customers to communicating and practicing the Golden Rule.
H creates an irrevocable
trust with W and his friend X as trustees to be the policy's applicants, owners and beneficiaries.
They funded the
trust with $15 million, which was invested in securities the income from which would be used to make the trust's required yearly charitable donations.
The TPT can be designed as a domestic trust or as a foreign
trust with stronger asset-protection features, yet be treated as a domestic trust for Federal income tax reporting purposes.
A
trust with a modest portfolio intended to fund education could have a relatively simple plan, while one planning for extensive real estate holdings that are intended to provide multiple generations of beneficiaries with income may have a much more complicated plan.
* Funding the
trust with sufficient cash to pay the premiums on an insurance Policy on the grantor's life.
In Scott, the individual trustees of a testamentary
trust with $25 million in assets paid investment advisory, custodian, trustees' and return preparation fees in 1996 and 1997.
Example 4: D is a grantor of a revocable
trust with $100,000 in assets.
This article examines important issues in funding a QTIP
trust with an IRA, including a recent IRS pronouncement that liberalized some of the rules.
The taxpayer creates an irrevocable
trust with beneficiaries that ultimately would receive his assets on death.
If the grantor were to sell a valuable asset on credit to the
trust with no net worth, the IRS might consider the transaction a sham.
Notwithstanding this and other unfavorable rulings, however, the Crummey battle appears one the taxpayer is likely to win in the long run, absent a legislative change.(21) In Holland,(22) the Tax Court again sided with the taxpayer in a case addressing a number of gift and estate tax issues, including transfers in
trust with Crummey powers.
A
trust with a zero inclusion ratio is exempt from GST tax.
This will be so even if each plan has the same benefit structure or plan document, or if all or part of the assets are invested in one
trust with separate accounting for each plan.