Contingent beneficiaries and Crummey powers: the battle lines are drawn
Article Abstract:
The IRS is continuing its attack on the use of Crummey trusts to obtain annual gift tax exclusions despite repeated losses in the US Tax Court. The Tax Court found in favor of the taxpayer on this issue in 1991 in Estate of Cristofani v. Commissioner and confirmed its position in a 1997 memorandum opinion in Estate of Kohlsaat v. Commissioner. The IRS has stated in several rulings that it believes taxpayers are creating Crummey trusts with contingent beneficiaries with the bona fide gift-giving intent that is required for a gift to be valid for tax purposes.
Publication Name: Journal of the American Society of CLU & ChFC
Subject: Law
ISSN: 1052-2875
Year: 1997
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Contingent workforce does not threaten permanent jobs
Article Abstract:
Temporary employment arrangements help employers respond to rapidly changing market conditions but supplement rather than replace permanent staff, according to National Assn of Temporary and Staffing Services Senior VP Edward A. Lenz. The advantages for employers include flexibility, adaptability to different seasonal labor needs and relief from benefits responsibilities. Temporary employees also benefit in that they learn new job skills and many find permanent jobs, often through the temp service. Temporary workers make up under 5% of all workers.
Publication Name: Labor Law Journal
Subject: Law
ISSN: 0023-6586
Year: 1995
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