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
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
Income Tax Issues
Deathbed Transfers

Estate of Moore v. Commissioner
T.C. Memo. 2020-40

On April 7, 2020, the Tax Court issued a Memorandum Opinion in the case of Estate of Moore v. Commissioner (T.C. Memo. 2020-40). The general issues before the court in Estate of Moore v. Commissioner were (1) whether the petitioner’s complex estate plan actually reduced the size of his taxable estate and (2) whether the petitioner’s estate planning resulted in unintended taxable gifts. The Tax Court answers these questions through a most thorough analysis of IRC

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Scott St. Amand April 7, 2020
Income Tax Issues
Admissibility of Evidence

Grieve v. Commissioner
T.C. Memo. 2020-28

On March 2, 2020, the Tax Court issued a Memorandum Opinion in the case of Grieve v. Commissioner (T.C. Memo. 2020-28). The primary issue presented in Grieve v. Commissioner was the valuation of the petitioner’s 99.8% member interests in two LLCs, Rabbit 1, LLC and Angus MacDonald, LLC, transferred to the petitioner from a GRAT and an irrevocable trust, respectively. Background to Grieve v. Commissioner – A Three Hour Tour This is the cautionary tale

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Scott St. Amand March 2, 2020
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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

Read More »
Scott St. Amand May 12, 2021

Estate of Moore v. Commissioner
T.C. Memo. 2020-40

On April 7, 2020, the Tax Court issued a Memorandum Opinion in the case of Estate of Moore v. Commissioner (T.C. Memo. 2020-40). The general issues before the court in Estate of Moore v. Commissioner were (1) whether the petitioner’s complex estate plan actually reduced the size of his taxable estate

Read More »
Scott St. Amand April 7, 2020

Grieve v. Commissioner
T.C. Memo. 2020-28

On March 2, 2020, the Tax Court issued a Memorandum Opinion in the case of Grieve v. Commissioner (T.C. Memo. 2020-28). The primary issue presented in Grieve v. Commissioner was the valuation of the petitioner’s 99.8% member interests in two LLCs, Rabbit 1, LLC and Angus MacDonald, LLC, transferred to

Read More »
Scott St. Amand March 2, 2020