Income Tax Issues
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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
All Articles

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
All Articles

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
All Articles

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
Tax Articles

Understanding the Doctrine of Constructive Receipt

Uncle Bill Sells the Buick Your dear Uncle Bill calls you all in a tizzy asking for some (free) legal advice from his “favorite” nephew. You want to remind him that you are (a) the only lawyer in the family, and (b) the only one of his nephews who not currently in the hoosegow, but you think better of it and indulge him. Bill and Aunt Ethel, who apparently are back together after the Thanksgiving

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Scott St. Amand April 30, 2021
Income Tax Issues
Tax Articles

The Deductibility of Criminal Restitution & The Claim of Right Doctrine

You have made it a habit to screen your calls, even since your mother gave Uncle Bill your direct line at work. Sure enough, 5:59 PM rolls around, and you have one foot physically out of your office door when your phone rings. Mother of all that is good and holy… As you put your briefcase down in the doorway and slowly amble back to your desk, you are at once relieved that it is

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Scott St. Amand April 29, 2021
Income Tax Issues
Tax Articles

A Deep Dive into Innocent Spouse Relief

Uncle Bill has four children…that he knows of. We met Jedediah in a previous post. Jethro is on year four of his five-year stint at Raiford for possession of amphetamines with intent to distribute. In his defense, Jethro agreed with the officer that the crank was his.  However, he vehemently denied that he had any intent whatsoever to share it with anyone else. (Candidly, you absolutely believe him.)  Bill and Ethel’s daughters Jennie and Jaime

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Scott St. Amand April 29, 2021
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Redefining Your Financial Outlook for Greater Life Success
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Norberg v. Commissioner
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Salter v. Commissioner
T.C. Memo. 2022-29

On April 5, 2022, the Tax Court issued a Memorandum Opinion in the case of Salter v. Commissioner (T.C. Memo. 2022-29). The primary issues presented in Salter v. Commissioner were (i) whether the Code section providing exception from imposition of additional tax resulting from early distribution from retirement plan applied;

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Scott St. Amand November 23, 2022