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
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.