Sales to Grantor Trusts
Sales to grantor trusts can be very beneficial for your clients, if done correctly. There are various ways to structure this transaction, each having its own pros and cons. The Woelbing case recently docketed in the U.S. Tax Court requires a de novo review of some of these drafting and planning strategies. Find out which structure is best for your client.
During this session the following topics will be covered.
- Assuring grantor trust status
- Balancing bet-to-live and bet-to-die strategies
- Intentionally Defective Grantor Trust (IDGT) strategies including
- Sales to IDGTs
- Structuring IDGT sales to avoid Sections 2701, 2702 and 2036 (and the Woelbing case)
- Sales to an IDGT with a SCIN hedge
- How to design note sales
- The truth about the 9 to 1 ratio
- The use of guarantees
- Applying Rev. Rul. 93-12 when your client has more than one child
- Protective clauses for revaluation including the Wandry, Petter, McCord, and Christianson cases
- Designing QTIPs, GRATs, and LPA overflow clauses
There will be no CE for this webinar
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