Charitable trust can be used to convey stock in close corp
Article Abstract:
The owner of a close corporation can use a charitable lead trust to give future generations of his family a deferred interest in the corporation's stock. The deferred interest mechanism makes it possible to give more stock and to give it free of estate tax liability. While the income tax deduction under IRC 170(a)(1) is generally not worthwhile, this is not true of the gift tax deduction under IRC 2522. Funding the trust so as to meet its deductibility and wealth transference aims is discussed, as is maintaining the liquidity necessary to make distributions.
Publication Name: Estate Planning
Subject: Law
ISSN: 0094-1794
Year: 1993
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Interaction of the GST tax and charitable trusts
Article Abstract:
Charitable lead or remainder trusts are subject to a large number of confusing IRC sections and compliance is further complicated when the beneficiary is a skip person. Generation skipping transfer (GST) tax can apply to either charitable trust if a skip person receives income or the remainder from the trust, causing some portion of the trust to be taxable. Therefore, it is important to appropriately apply the $1 million GST exemption but that is difficult because the GST inclusion ratio is not determinable when the transfers are made.
Publication Name: Estate Planning
Subject: Law
ISSN: 0094-1794
Year: 1995
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Planning for possible pretermitted children and pretermitted spouses
Article Abstract:
Children or spouses omitted from wills may be able to claim part of an estate. Most states have statutes to protect children in this situation, although the challenge is to determine whether the children were omitted intentionally or not. Pretermitted children and spouses must usually be specifically excluded from the estate. Estate planners who attempt to fulfill client expectations should anticipate the possibility of pretermitted children and spouses.
Publication Name: Estate Planning
Subject: Law
ISSN: 0094-1794
Year: 1997
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