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
Estate Tax

Estate of Morrissette v. Commissioner
T.C. Memo. 2021-60

On May 12, 2021, the Tax Court issued a Memorandum Opinion in the case of Estate of Morrissette v. Commissioner (T.C. Memo. 2021-60). The primary issue presented in Estate of Morrissette v. Commissioner was whether IRC § 2036 or IRC § 2038 applies to recapture significant inter vivos transfers made as part of the split-dollar agreements, and, if not, whether the special valuation rule of IRC § 2703 applies to require that the valuation disregard a

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Scott St. Amand May 12, 2021
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Estate of Morrissette v. Commissioner
T.C. Memo. 2021-60

On May 12, 2021, the Tax Court issued a Memorandum Opinion in the case of Estate of Morrissette v. Commissioner (T.C. Memo. 2021-60). The primary issue presented in Estate of Morrissette v. Commissioner was whether IRC § 2036 or IRC § 2038 applies to recapture significant inter vivos transfers made as

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Scott St. Amand May 12, 2021