 |
    
|
 |
 |
      |
|
Grantor Trusts Source: Estate & Succession Planning Corner Authors: Lawrence I. Richman Related Areas: Private Wealth Services May-June 2010 For domestic (U.S.) grantor trusts, there are two sets of rules under Subchapter J, Part E, of the Internal Revenue Code; the grantor grantor trust rules of Code Secs. 671-677 and the benefi ciary grantor trust rules of Code Sec. 678. Recently, LTR 200949012 was published.3 The issue in LTR 200949012 was whether the trust in question would be treated as a grantor grantor trust, a beneficiary grantor trust, or as an irrevocable trust taxable under the distributable net income (DNI) rules of Subchapter J, Parts A-D. Under the facts presented, the grantor’s role was limited to the creation of the trust and the transfer of property to it. Neither the grantor nor the grantor’s spouse was a benefi ciary of the trust, had any interest in the trust, could be the recipient of income or principal from the trust, or could be benefi ted through the payment of premiums of insurance on their life. Neal Gerber Eisenberg Private Wealth Services partner Lawrence I. Richman authored this article.  Click here to view full article (PDF). |
|
|
|
|
|