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.
16040 provides that the trustee must administer the trust with
reasonable care, skill and caution under the then-prevailing circumstances that a prudent person acting in a like capacity would use in the conduct of an enterprise of like character and with like aims to accomplish the purposes of the trust as determined from the trust instrument.
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.
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.
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.
A trust with
a zero inclusion ratio is exempt from GST tax.
However, under a transition rule in the statute, a domestic trust with
a foreign grantor treated as its owner under present law that becomes a foreign trust as a result of the new rules will be exempt from the Sec.
First, inadvertently, no GST exemption has been previously allocated to a trust with
appreciable assets and one or more potential skip-person beneficiaries, in which there have been transfers made by gift in previous years.
The notes initially carried zero interest, paying interest only after a trust with
respect to which the note was issued ceased to be a grantor trust.
672(f)(2), as amended, provides that a trust with
a foreign grantor will nevertheless be a grantor trust if (1) the grantor can revest in himself title to trust property without another's approval or consent or with the consent of a related or subordinate party subservient to the grantor or (2) during the grantor's lifetime, the only amounts distributable (whether income or corpus) from the portion of the trust treated as owned by the grantor are amounts distributable to the grantor or his spouse.