Special Bundle of 3 Webinars:

Edwin Morrow - April 25, 2018 3:00 PM EDT - 4:00 PM EDT ET
INGs and Spousal Lifetime Access Non-Grantor Trusts (SLANTs) – Not Just for State Income Tax Avoidance: How Tax Reform Makes "INGs" and "SLANTs" Even More Powerful

Edwin Morrow and Marty Shenkman April 26, 2018 3:00 PM EDT - 4:00 PM EDT ET
Non-Grantor Trusts (including INGs and SLANTs): Avoiding State Income Tax, Including New York City and State, and Avoiding "Source Income"


INGs and Spousal Lifetime Access Non-Grantor Trusts (SLANTs) - Not Just for State Income Tax Avoidance: How Tax Reform Makes "INGs" and "SLANTs" Even More Powerful

Recording and Slides are Available Here.

INGs and Spousal Lifetime Access Non-Grantor Trusts – Not Just for State Income Tax Avoidance: How “INGs” and “SLANTs” Can Save State Income Taxes and Why Tax Reform Makes Them Even More Powerful 

Incomplete Gift, Non-Grantor Trusts (“INGs”) have been steadily increasing in use.  The reduction in deduction for state income taxes and continuingly favorable court decisions will only make them more so.  Additionally, the doubling of the estate/gift/GST exemption and the new tax reform scheme vis a vis deductions for state income tax, de facto elimination of the charitable deduction for many and the new 20% deduction for qualified business income may also cause an increase in the use of completed gift non-grantor trusts (when’s the last time you considered one of those!). 

While INGs and SLANTs sound simple on the surface, like most estate and tax planning techniques the “devil is in the details” and they have deeper, more complex issues that need to be addressed if they are to be utilized properly. In this webinar, Ed will cover:

  • The unique ING trust structure approved in the key PLRs, including the most recent favorable rulings involving the preservation of community property.
  • Which states are best for using INGs to avoid state income tax.
  • Which states are best for using SLANTs to avoid state income tax (they may be different!).
  • Overlooked design options to legitimately avoid some state trust residency rules (along with an examination of several recent state and U.S. Supreme Court decisions on the constitutional limits of these residency rules)
  • How some states’ “source income” rules apply, regardless of a taxpayer’s residency and how to avoid state income tax for most clients’ most likely largest taxable event – the sale of a closely held business or pass through entities holding real estate and business interests (material includes a 50 state chart which not only includes the simpler trust residency rules, but also the more varied and complex source income rules applicable to sales of intangibles and entities).
  • The overlooked federal income tax benefits possible with such trusts, such as avoiding the 3.8% surtax applicable to passive business owner income, as well as income tax shifting, exploitation of more favorable charitable deductions, the new Section 199A qualified business income deduction
  • Where’s the comfort level of “relying” on PLRs – what part of INGs is clearly supported in the tax code, regulations or other substantial authority - and what is not?
  • Why New York’s legislative response to INGs will NOT become widely adopted by other states (and, how to exploit the loopholes left open using SLANTs)
  • Common administration traps that might trip up non-grantor trust status
  • How to exploit regulations to trap capital gains inside the trust for tax purposes, even if they are distributed (and how ESBTs can trap non-capital gains income in trust even if income is distributed)
  • Traps and opportunities with loans, investments and purchases to and from DINGs and NINGs
  • Why politicians love INGs and how they can use them to exploit a little known new tax code section buried deep within the PATH Act!
  • How to defer gains via installment sales to INGs at least two years prior to sale of a business.
  • How using INGs in conjunction with charitable remainder unitrusts (CRUTs) will often be much, much more tax efficient than ordinary CRUTs (and why you need to know how to avoid the unrelated business income tax or “UBIT” rules)

There will be no CE for this webinar

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Non-Grantor Trusts (including INGs and SLANTs): Avoiding State Income Tax, Including New York City and State, and Avoiding "Source Income"

Recording and Slides are Available Here.

Using Non-Grantor Trusts, Including INGs and SLANTs, and Avoiding State Income Tax, Including New York City and State

This session will build on the prior day’s webinar on INGs and SLANTs and concentrate on state income tax issues.  How do the various states tax non-grantor trusts (and where are the loopholes)?  Just as importantly, how and when do states tax “source income” even for non-residents and non-resident trusts, especially for LLCs/LPs and other closely held businesses?  A 50 state plus D.C. chart will be provided with links to statutes in this area.

We’ll initially tackle New York, which has specific legislation combatting incomplete gift, non-grantor trusts (INGs) and closes other loopholes, but to borrow a phrase, “if you can make state tax avoidance work there, you can make it anywhere”.  We’ll cover other states as well and these important concepts:

-        Increased impact of state income tax after new SALT limitations

-        Differences between INGs and SLANTs and BDIT/BDOTs vis a vis state income tax

-        Unique opportunity for QTIP/SLANTs to avoid state income tax on capital gain

-        New York’s exempt resident trust rules

-        California and New York throwback rules

-        Importance of considering non-traditional trustee/advisor/protector location for nexus

-        Quick overview of the state of Constitutional litigation defeating state tax overreach

-        Important source income rules, including the Uniform Division of Income for Tax Purposes Act

-        Source income variance among the states for sales of partnerships, LPs, LLCs and C/S corps (and why you shouldn’t trust some of the various compiled charts in this area)

-        Exploiting INGs/SLANTs for QBI and SALT deductions even if there is unavoidable source income

There will be no CE for this webinar


Proceedings from the 44th Annual Notre Dame Tax & Estate Planning Institute

Recording and Slides are Available Here.

Couldn’t attend the  44th Annual Notre Dame Tax and Estate Planning Institute? LISI has the next best thing to being there!
On Tuesday, October 23rd, join program director Jerry Hesch and Notre Dame Institute presenters Alan Gassman and  Marty Shenkman and for their exclusive LISI webinar where they will provide you with a snapshot overview of all the proceedings from this amazing conference.
As in the past, this year’s Institute provided topics focused on income tax planning, planning with non-grantor trusts, addressing new Section 199A, the new Proposed Regulations for 199A and 643(f), elimination or deferral of state income taxes, and much more. With dual sessions, individuals attending the Institute could choose topics relevant to their clients. Here’s a quick look at what Jerry, Alan, Ed and Marty will cover:

    • Explaining and Planning Through the 199A Minefield
    • Using Estate Planning Techniques for Your Client’s Income Tax Planning
    • Using Non-Grantor Trusts for Estate and Income Tax Planning
    • Current Developments of Importance to Estate Planners
    • Estate Planning for the Modern Family: Special Considerations and Drafting Tips
    • Life Insurance Product Selection, Design and Funding
    • Preparing the 706: Traps, Mistakes and Omissions
    • Estate and Business Planning for Farm and Ranch Clients: Unique Issues and Traps to Avoid
    • Ten Things Every Estate Planner Needs to Know About Subchapter J
    • Managing Tax Basis Today for Tomorrow
    • Donor Advised Funds, Community Foundations, Private Foundations and 501(c)(4) Charities
    • Estate Planning Income Tax, Financial and Personal Objectives
    • Ethical and Practical Obstacles in Retaining Important Clients

    There will be no CE for this webinar

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