Trusts Serving as Grantors to Other Trusts: Drafting Multi-Trust Structures for Optimal Tax Results
Essential language in Grantor and Grantee Trusts
Recording of a 90-minute CLE/CPE webinar with Q&A
This CLE/CPE course will provide estate planners with a practical guide to the tax consequences of structuring trusts that own other trusts. The panel will discuss critical drafting language in both the grantor and grantee trust, and outline potential tax saving opportunities and risks in multi-trust structures.
Outline
- Grantor Trust Rules of Sections 671-678
- Options for structuring secondary trusts
- Original grantor as grantor of Trust II
- Beneficiary as a grantor of Trust II
- Trust II as a complex trust
- Critical drafting language to accomplish intended status
- Letter Ruling 201633021: Trust I as grantor of Trust II
- Planning opportunities and risks
Benefits
The panel will review these and other key issues:
- Various tax results that are possible when one trust establishes and funds a new trust
- Recommended provisions to accomplish the desired tax results
- Potential risks of using trusts as grantors to other trusts
- Possible impact of PLR 201633021
Faculty
Andrew S. Katzenberg
Senior Counsel
Kleinberg Kaplan Wolff & Cohen
Mr. Katzenberg focuses primarily on wealth transfer planning and preservation, multi-generational planning, estate and... | Read More
Mr. Katzenberg focuses primarily on wealth transfer planning and preservation, multi-generational planning, estate and trust administration, nonprofit and tax exempt organizations and charitable giving. He works with a variety of high net-worth clients and also represents clients in all phases of forming and managing nonprofit and tax exempt organizations (including public charities, private foundations and private operating foundations) and acquiring and retaining their tax exempt status. He authored numerous articles related to his field and is a frequent contributor to the New York State Bar Association’s Trusts and Estates Law Section Newsletter.
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Ruth Mattson
Principal
Bove & Langa
Ms. Mattson advises trustees and personal representatives with the administration of trusts and estates, including... | Read More
Ms. Mattson advises trustees and personal representatives with the administration of trusts and estates, including local and multinational trusts and estates. She focuses on international planning, including planning for overseas assets, forming offshore asset protection trusts, planning for a spouse who is not a U.S. citizen, and helping U.S. beneficiaries plan to receive gifts and inheritances from abroad. For clients with unreported foreign assets, she coordinates with accountants to help bring the clients into compliance with their FBAR and other reporting requirements.
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