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BBA Webinar: Gifts and Sales to Intentionally Defective Grantor Trusts & Use of High Exemption Levels in 2020 - 2021

Monday, November 16, 2020 12:30 PM to 1:30 PM
On-Line


Description:

The BBA presents live webinars and virtual events via Zoom. Please register for this program through your BBA account at least two hours before the start time of the program to receive the Zoom webinar link.

This seminar will provide an overview of the structure, tax treatment and proper administration of gifts and sales to intentionally defective grantor trusts (“IDGTs”). Some of the structuring topics we will discuss include:

    • proper trust drafting to ensure estate tax exclusion and grantor trust status for income tax purposes,
    • how to choose the right assets to transfer to an IDGT,
    • “entitizing” assets,
    • the proper documentation needed for a “gift” and/or “sale” of assets, including the use of “defined value” (Wandry) and “price adjustment” (King) language,
      timing issues,
    • debt v. equity issues,
    • ensuring sufficient cash flows,
    • the proper administration of the IDGT after the transfers, and
    • the presenters’ recent audit experience and the IRS’ hostility to the strategy.
       

We will also focus on the tax benefits including: (i) leveraging assets through use of value-freezing techniques and discounts, (ii) maximizing use of GST exemption, and (iii) optimal benefits of grantor trust status as a means to further deplete the grantor’s estate without consuming exemption and avoid income taxes upon the sale of assets and payments under any promissory note.

This seminar will further discuss why it may be critical to advise clients about using the enhanced wealth transfer tax exemptions now in light of possible post-election reforms.  

Registration Categories:

BBA Member - Free. Included as part of your membership.

Non-Member - $100.00

BBA Webinars & Virtual Events are supported by the Joan B. DiCola Fund. To learn more or support this fund, click here.

Sponsoring Section/Committee(s):

Speakers:

 

Contact:

Jenna Kim
jkim@bostonbar.org

 

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