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Sales to Grantor Trusts – In a Low Interest Rate Economy - 2020 Update



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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.  Find out which structure is best for your client in today’s tax and economic environment.
During this session the following topics will be covered.

o    Assuring grantor trust status
o    Taking advantage of our low interest rates
o    Choice of Situs
o    Balancing bet-to-live and bet-to-die strategies
o    Intentionally Defective Grantor Trust (IDGT) strategies including
o    Designing the “tax-burn” and the “tax-burn SCIN”
o    Sales to IDGTs
o    Structuring IDGT sales to avoid Sections 2701, 2702 and 2036 (and the Woelbing case)
o    Sales to an IDGT with a SCIN hedge
o    How to design note sales to assure debt treatment
o    Choosing the length of notes
o    The truth about the 9 to 1 ratio
o    The use of guarantees
o    Applying Rev. Rul. 93-12 when your client has more than one child
o    Protective clauses for revaluation including the Wandry, Petter, McCord, and Christianson cases
o    Designing QTIPs, GRATs, and LPA overflow clauses
o    Audit proofing your design and gift tax returns




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Robert S. Keebler, CPA/PFS, MST, AEP (Distinguished) is a partner with Keebler & Associates, LLP and is a 2007 recipient of the prestigious Accredited Estate Planners (Distinguished) award from the National Association of Estate Planners & Councils. He has been named by CPA Magazine as one of the Top 100 Most Influential Practitioners in the United States and one of the Top 40 Tax Advisors to Know During a Recession. Mr. Keebler is the past Editor-in-Chief of CCH's magazine, Journal of Retirement Planning, and a member of CCH's Financial and Estate Planning Advisory Board. His practice includes family wealth transfer and preservation planning, charitable giving, retirement distribution planning, and estate administration. Mr. Keebler frequently represents clients before the National Office of the Internal Revenue Service (IRS) in the private letter ruling process and in estate, gift and income tax examinations and appeals. In the past 20 years, he has received over 250 favorable private letter rulings including several key rulings of ""first impression."" Mr. Keebler is nationally recognized as an expert in estate and retirement planning and works collaboratively with other experts on academic reviews and papers, and client matters. Mr. Keebler is the author of over 75 articles and columns and editor, author, or co-author of many books and treatises on wealth transfer and taxation, including the Warren, Gorham & Lamont of RIA treatise Esperti, Peterson and Keebler/Irrevocable Trusts: Analysis with Forms. Mr. Keebler is the Chair of the AICPA's Advanced Estate Planning Conference. He is a featured columnist for CCH's Taxes Magazine - ""Family Tax Planning Forum,"" Bob is also a contributing author to the American Bar Association's The ABA Practical Guide to Estate Planning. Robert.Keebler@KeeblerandAssociates.com


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