Income Tax Issues
Beneficiary

Grantor Trusts – Part IV of IV – Retained Powers and Non-Grantor Owners

In Part I of this series on Grantor Trusts, we look at the nature of trusts in general.  In Part II, we shift to a look at grantor trusts, and a few definitional rules.  In Part III and Part IV, we take a deep dive into the interests that a grantor may retain that will cause a trust to be treated as a grantor trust as well as instances in which a person other than

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Scott St. Amand July 5, 2021
Income Tax Issues
Beneficiary

Grantor Trusts – Part III of IV – Reversionary Interests and Powers to Control Beneficial Enjoyment

In Part I of this series on Grantor Trusts, we look at the nature of trusts in general.  In Part II, we shift to a look at grantor trusts, and a few definitional rules.  In Part III and Part IV, we take a deep dive into the interests that a grantor may retain that will cause a trust to be treated as a grantor trust as well as instances in which a person other than

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Scott St. Amand July 5, 2021
Income Tax Issues
Beneficiary

Grantor Trusts – Part II of IV – Introduction to Grantor Trusts

In Part I of this series on Grantor Trusts, we look at the nature of trusts in general.  In Part II, we shift to a look at grantor trusts, and a few definitional rules.  In Part III and Part IV, we take a deep dive into the interests that a grantor may retain that will cause a trust to be treated as a grantor trust as well as instances in which a person other than

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Scott St. Amand July 5, 2021
Income Tax Issues
Fiduciary Duties

Grantor Trusts – Part I of IV – Introduction to Trusts and Taxes

When I told my boss that I was going to write an article on grantor trusts, he responded (without hesitation sensitivity, or thought), “You know, a lot of people have written about grantor trusts.” He’s not wrong. Not helpful—but not wrong Search Google, and you will find numerous websites with cursory discussions on grantor trusts.  Look a little deeper, and you may even find some of the very good scholarly articles that I drew from

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Scott St. Amand July 5, 2021
Income Tax Issues
Burden of Proof

Sage v. Commissioner (154 T.C. No. 12)

On June 2, 2020, the Tax Court issued its opinion in Sage v. Commissioner (154 T.C. No. 12). The issue presented in Sage v. Commissioner was whether the petitioner, who wholly owned an S corporation and LLC, which in turn owned (indirectly) and transferred three encumbered properties to separate liquidating trusts that disposed of the parcels with the profits going to pay off the liabilities of the S corporation and LLC, was the owner/grantor of

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Scott St. Amand June 2, 2020
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Sage v. Commissioner (154 T.C. No. 12)

On June 2, 2020, the Tax Court issued its opinion in Sage v. Commissioner (154 T.C. No. 12). The issue presented in Sage v. Commissioner was whether the petitioner, who wholly owned an S corporation and LLC, which in turn owned (indirectly) and transferred three encumbered properties to separate liquidating

Read More »
Scott St. Amand June 2, 2020