The benefits of charitable remainder trusts
Article Abstract:
Charitable remainder trusts (CRT) can provide income and estate tax benefits as well as increasing the donor's level of income while alive and achieving the donor's charitable intentions. CRTs can take the form of an annuity trust, net income unitrust, standard unitrust or net income with makeup unitrust. The tax benefits include an income tax deduction during the donor's life of the remainder interest's value, estate tax deduction of the value and tax exemption of trust income. However, the IRS may deny CRT status if the trust is exhausted and so careful planning is important.
Publication Name: Journal of the American Society of CLU & ChFC
Subject: Law
ISSN: 1052-2875
Year: 1992
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Valuation of buy-sell agreements under chapter 14 of the Internal Revenue Code
Article Abstract:
IRC chapter 14 contains many complicated provisions relating to taxation and valuation of buy-sell agreements that make solid tax planning difficult. Buy-sell agreements, both redemption and cross-purchase, can create capital gains, taxable income and the need for estate and transfer taxes. Tax planners must be aware of the Omnibus Budget Reconciliation Act of 1990's valuation rules concerning transfer tax, establish buy-sell agreements that comply with arm's length transaction requirements and carefully document all factual data supporting their positions.
Publication Name: Journal of the American Society of CLU & ChFC
Subject: Law
ISSN: 1052-2875
Year: 1992
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Proper use and abuse of familial limited partnerships
Article Abstract:
IRS Technical Advice Memorandum 97-6842 demonstrates the careful planning that is necessary to avoid the IRS's disregarding of the business form of family limited partnership. The IRS disfavors the form as a vehicle instituted to avoid estate tax and lacking in business purpose. The IRS's denial of the benefits of IRC valuation section 2703 is not based upon its own or judicial precedent.
Publication Name: Journal of the American Society of CLU & ChFC
Subject: Law
ISSN: 1052-2875
Year: 1998
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