Using the rationale of Reg. s. 25.2702-6 in other estate tax computations

Article Abstract:

Treasury regulation s 25.2702-6 prevents double taxation on trust transfers under IRC section 2702 but can also be used for the same purpose under section 2001(b). The regulation provides a computational methodology to downwardly adjust prior taxable gifts that are included in the gross estate and can be used for many estate tax situations beyond the incomplete gift tax coverage of 2702. Some of these situations include transfers in trust that are included in the gross estate but still treated as completed gifts and transfers to non-family members when an interest is retained.

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Trust estate freeze valuation rules under the final section 2702 regulations

Article Abstract:

IRC section 2702 final regulations clarify the Revenue Reconciliation Act of 1990's special valuation rules for estate freeze techniques involving transfers in trusts such as grantor retained income trusts. The special valuation rules assume the value of a retained interest is zero unless the interest is a qualified interest which is then actuarially valued under section 7520. The tax values for estate freezing trust transfers are severely reduced under the new rules except for personal residence or qualified personal residence trusts, but these must meet strict requirements.

Methods, Estate planning

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Corporate estate freeze valuation rules under the proposed Section 2701 regulations

Article Abstract:

Proposed regulations issued on Apr 4, 1991 help to clarify the application of special valuation rules to corporate estate freezes under Section 2701. Section 2701 replaces Section 2036(c), changing from an estate tax approach to a gift tax approach. The regulations cover scope of application of special valuation rules, use of the subtraction method for valuation of the transferred interest, valuation of retained interests, qualified payment elections, attribution rules and compounding rules.

Special use valuation (Taxation)

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