Download or read book The Grantor Trust Rules Should Be Repealed written by Mark L. Ascher and published by . This book was released on 2011 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The grantor trust rules once served a crucial role. They limited taxpayers' ability to gain income tax advantages from creating certain types of inter vivos trusts, by denying them separate taxpayer status and providing that their income was taxable directly to the grantor. But times change. In 1986, Congress dramatically compressed the tax brackets in section 1(e), thereby imposing a flat tax, at the highest marginal rate, on essentially all trust income. It is now impossible for a settlor to derive any substantial income tax advantage from subjecting trust income to taxation at the trust's own rates, because neither the settlor nor any of the trust beneficiaries is ever going to be in a higher tax bracket than the trust, as to any meaningful amount of income. Yet that is precisely the fact pattern that gave rise to the grantor trust rules. The grantor trust rules are, therefore, obsolete. Indeed, taxpayers and their advisors now gleefully stand the grantor trust rules on their head, creating so-called "intentionally defective grantor trusts," and laugh about it all the way to the bank. All that remains of the grantor trust rules are their complexity and the opportunities they provide to game the system. They are both obsolete and counter-productive, and they ought to be repealed.

Download or read book Tax Reform Paul McDaniel Style written by Laura Cunningham and published by . This book was released on 2011 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: In this essay, which is to be published as part of a Festschrift in the memory of Paul McDaniel (forthcoming, Kluwer Law International), we argue that repeal of the grantor trusts rules would represent real tax reform in the Paul McDaniel sense. The grantor trust rules are not tax expenditures; they are structural provisions of the Code that were enacted for vertical equity reasons, to preserve the progressivity of the income tax rate structure. We believe that not only do they no longer serve their original purpose, they actually defeat that purpose today. They are being used by wealthy taxpayers to avoid transfer taxes. This not only creates equity problems within the transfer tax system, it has the ripple effect of reducing progressivity of the overall federal tax system. Repeal of these provisions would represent significant and important tax reform.

Download or read book Reforming the Grantor Trust Rules written by Jay A. Soled and published by . This book was released on 2014 with total page 49 pages. Available in PDF, EPUB and Kindle. Book excerpt: Few things in the Internal Revenue Code (Code) are as enduring as the grantor trust rules. Housed in Subpart E of Subchapter J of the Code, they are essentially the same rules that were instituted by the so-called Clifford trust regulations promulgated over a half-century age. In instances where the grantor trust rules apply, the Code ignores the separate existence of a trust. Items of income, deductions, and credits against tax are instead attributed to the grantor. Grantors are thus unable to deflect income away from themselves to others (such as a trust or a trust beneficiary) whose income is taxed at a lower marginal rate. The purpose of the grantor trust rules then, and their purpose now, is to safeguard the progressive rate structure of the income tax.

Download or read book Income Taxation of Trusts and Estates written by Alan S. Acker and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: "... provides detailed coverage of the rules governing the income taxation of estates, trusts, and their beneficiaries"--Page iii.

Download or read book Understanding Grantor Trust Rules written by George L. Cushing and published by . This book was released on 1998 with total page 73 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Grantor Trusts sections 671 679 written by Robert T. Danforth and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: ... examines the taxation of grantors and third parties deemed to own the assets of a trust under [section] 671–[section] 679. The planning and drafting of trusts requires a clear understanding of the grantor trust rules in order to ensure that the grantor, trust, and beneficiaries are taxed in the desired fashion.

Download or read book Grantor Trust Answer Book 2017 written by Steven G. Siegel and published by . This book was released on 2016-11-02 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: A grantor trust is a trust in which the settlor retains control over the trust property or its income to such an extent that the settlor is taxed on the trust's income. The use of grantor trust arrangements has become an important estate planning tool. Owners of grantor trusts may be shareholders of S corporations. A number of desirable and sophisticated estate planning arrangements involve grantor trust status as the starting point. These include grantor retained annuity trusts (GRATs), grantor retained unitrusts (GRUTs), personal residence trusts (PRTs), qualified personal residence trusts (QPRTs) and intentionally defective grantor trusts (IDGTs).The Grantor Trust Answer Book addresses the following:. The grantor trust rules can be found in Code Sections 671 through 679. Each of these Sections describes a particular set of rules and circumstances that will cause a trust to be treated as a grantor trust. Each of these Code Sections is discussed in a separate Chapter addressing its rules and requirements.. Some of the interests retained by a grantor that make a trust a grantor trust also cause inclusion of the trust property in the grantor's estate. Other interests do not. These distinctions are discussed throughout the publication.. Separate chapters address the estate planning uses of all types of grantor trusts (GRATs and GRUTs, PRTs and QPRTs, IDGTs).. Grantor trust issues are involved in the design of certain charitable trusts, notably charitable lead trusts and these are discussed in detail. . Coverage of foreign grantor trusts which is increasingly a topic of planning interest and government concern is included as well. . The fact that grantor trusts are subject to special income tax filing and reporting rules is discussed.. The role grantor trusts may have in planning for life insurance ownership, like kind exchanges and involuntary conversions are also among the issues addressed.

Download or read book Grantor Trust Answer written by Steven G. Siegel and published by Cch. This book was released on 2017-11-10 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: A grantor trust is a trust in which the settlor retains control over the trust property or its income to such an extent that the settlor is taxed on the trust's income. The use of grantor trust arrangements has become an important estate planning tool. Owners of grantor trusts may be shareholders of S corporations. A number of desirable and sophisticated estate planning arrangements involve grantor trust status as the starting point. These include grantor retained annuity trusts (GRATs), grantor retained unitrusts (GRUTs), personal residence trusts (PRTs), qualified personal residence trusts (QPRTs) and intentionally defective grantor trusts (IDGTs). The Grantor Trust Answer Book addresses The grantor trust rules can be found in Code Sections 671 through 679. Each of these Sections describes a particular set of rules and circumstances that will cause a trust to be treated as a grantor trust. Each of these Code Sections is discussed in a separate Chapter addressing its rules and requirements. Some of the interests retained by a grantor that make a trust a grantor trust also cause inclusion of the trust property in the grantors estate. Other interests do not. These distinctions are discussed throughout the publication.

Download or read book International Taxation of Trust Income written by Mark Brabazon and published by Cambridge University Press. This book was released on 2019-05-02 with total page 417 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust and will appeal to international tax practitioners, administrators, policymakers, academics, and students.

Download or read book Rethinking Estate and Gift Taxation written by William G. Gale and published by Rowman & Littlefield. This book was released on 2011-07-01 with total page 544 pages. Available in PDF, EPUB and Kindle. Book excerpt: Although estate and gift taxes raise a small fraction of federal revenues, they have become sources of increasing political controversy. This book is designed to inform the current policy debate and build a conceptual basis for future scholarship. The book contains eleven original studies of estate and gift taxes, along with discussants' comments. The essays provide background and historical information; analyze the optimal taxation of estates and gifts; examine the effects of the tax on charitable contributions, saving behavior, the distribution and level of wealth, tax avoidance and tax evasion; and explore the effects of alternatives to estate taxation.

Download or read book Description of Revenue Provisions Contained in the President s Fiscal Year Budget Proposal written by and published by . This book was released on 2012 with total page 824 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Grantor Trust Answer Book 2016 written by Steven G. Siegel and published by . This book was released on 2015-12-21 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: A grantor trust is a trust in which the settlor retains control over the trust property or its income to such an extent that the settlor is taxed on the trust's income. The use of grantor trust arrangements has become an important estate planning tool. Owners of grantor trusts may be shareholders of S corporations. A number of desirable and sophisticated estate planning arrangements involve grantor trust status as the starting point. These include grantor retained annuity trusts (GRATs), grantor retained unitrusts (GRUTs), personal residence trusts (PRTs), qualified personal residence trusts (QPRTs) and intentionally defective grantor trusts (IDGTs). The Grantor Trust Answer Book addresses the following: . The grantor trust rules can be found in Code Sections 671 through 679. Each of these Sections describes a particular set of rules and circumstances that will cause a trust to be treated as a grantor trust. Each of these Code Sections is discussed in a separate Chapter addressing its rules and requirements. . Some of the interests retained by a grantor that make a trust a grantor trust also cause inclusion of the trust property in the grantors estate. Other interests do not. These distinctions are discussed throughout the publication. . Separate chapters address the estate planning uses of all types of grantor trusts (GRATs and GRUTs, PRTs and QPRTs, IDGTs). . Grantor trust issues are involved in the design of certain charitable trusts, notably charitable lead trusts and these are discussed in detail. . Coverage of foreign grantor trusts which is increasingly a topic of planning interest and government concern is included as well. . The fact that grantor trusts are subject to special income tax filing and reporting rules is discussed. . The role grantor trusts may have in planning for life insurance ownership, like kind

Download or read book Effects of the Federal Estate Tax on Farms and Small Businesses written by United States. Congressional Budget Office and published by . This book was released on 2005 with total page 60 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book General Explanation of the Tax Reform Act of 1986 written by and published by . This book was released on 1987 with total page 1400 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book The Federal Estate Tax written by David Joulfaian and published by MIT Press. This book was released on 2024-02-06 with total page 213 pages. Available in PDF, EPUB and Kindle. Book excerpt: A comprehensive and accessible account of the U.S. estate tax, examining its history and evolution, structure and inner workings, and economic consequences. Governments have been levying some form of inheritance tax since the ancient Egyptians did so in the seventh century BC. In the United States, the federal government experimented with various forms of inheritance taxes, settling on an estate tax in 1916 and a gift tax in 1932. Despite this long history, there are few empirical studies of the federal estate tax. This book offers the first comprehensive look at U.S. estate and inheritance taxes, examining their history and evolution, structure and inner workings, and economic consequences. Written by David Joulfaian, a veteran economist at the U.S. Department of the Treasury, the book provides accessible accounts of such topics as changes in tax laws, issues of equity, the fiscal contribution of the estate tax, and its behavioral effects. Joulfaian traces the evolution of U.S. inheritance taxes from 1797 to the present, noting that the estate tax rate and base expanded through 1976, then began to decline. He describes the tax itself, explaining that it currently applies to estates and gifts in excess of $11.18 million, and outlines applicable deductions and credits. He sketches a profile of taxpayers and their beneficiaries; surveys the revenues from estate and gift taxes; and discusses the effect of estate taxation on labor decisions, saving and wealth accumulation, charitable giving, life insurance ownership, and other economic activities. Finally, he addresses criticisms of the estate tax and analyzes its shortcomings. Accompanying tables present a wealth of data gathered by Joulfaian in his research and not available elsewhere.

Download or read book Trust Taxation written by Emma Chamberlain and published by . This book was released on 2011 with total page 1679 pages. Available in PDF, EPUB and Kindle. Book excerpt: Trust Taxation covers the taxation of UK resident and non-resident trusts explaining in detail the income tax, capital gains tax and inheritance tax treatment of the various different types of trusts. The book covers the tax consequences of creating and ending a trust, as well as the tax issues to consider during the lifetime of each type of trust and on distributions to beneficiaries. Part 1 contains an overview of trust law including recent case law on Hastings Bass, the categorisation of foreign entities, the new domicile and residence proposals and case law on residence and domicile generally. It also summaries the tax rules for foreign domiciliaries. Parts 2 to 4 explain the relevant legislation in detail as it relates to trusts, including discussion of entrepreneurs' relief, rollover relief, reservation of benefit, excluded property and relevant property trusts. Part 5 deals with special situations, including the family home, chattels, employee benefit trusts, pilot trusts, bare trusts, disabled trusts, will drafting, variations, business property relief and agricultural property relief, divorce and trusts.

Download or read book Grantor Trust Answer Book 2015 written by Steven G. Siegel and published by . This book was released on 2014-12-19 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: A grantor trust is a trust in which the settlor retains control over the trust property or its income to such an extent that the settlor is taxed on the trust's income. The use of grantor trust arrangements has become an important estate planning tool. Owners of grantor trusts may be shareholders of S corporations. A number of desirable and sophisticated estate planning arrangements involve grantor trust status as the starting point. These include grantor retained annuity trusts (GRATs), grantor retained unitrusts (GRUTs), personal residence trusts (PRTs), qualified personal residence trusts (QPRTs) and intentionally defective grantor trusts (IDGTs). The Grantor Trust Answer Book addresses the following: . The grantor trust rules can be found in Code Sections 671 through 679. Each of these Sections describes a particular set of rules and circumstances that will cause a trust to be treated as a grantor trust. Each of these Code Sections is discussed in a separate Chapter addressing its rules and requirements. . Some of the interests retained by a grantor that make a trust a grantor trust also cause inclusion of the trust property in the grantors estate. Other interests do not. These distinctions are discussed throughout the publication. . Separate chapters address the estate planning uses of all types of grantor trusts (GRATs and GRUTs, PRTs and QPRTs, IDGTs). . Grantor trust issues are involved in the design of certain charitable trusts, notably charitable lead trusts and these are discussed in detail. . Coverage of foreign grantor trusts which is increasingly a topic of planning interest and government concern is included as well. . The fact that grantor trusts are subject to special income tax filing and reporting rules is discussed. . The role grantor trusts may have in planning for life insurance ownership, like k