These temporary larger exemption amounts have prompted many to consider establishing Qualified Personal Residence Trusts
with large remainder interests, gifting business interests creating minority and lack of marketability discounts and establishing multi-generational education trusts.
Qualified personal residence trusts
(QPRTs) and personal residence trusts (PRTs) are other special forms of a GRIT.
Chamberlain, Florida Homestead Transfers: The Advantages of Short-term Qualified Personal Residence Trusts
, 76 Fla.
Complex trusts, such as qualified personal residence trusts
and grantor retained annuity trusts, pose the additional problem of the estate tax inclusion period (ETIP).
Also covered are equity strips, private annuities, and qualified personal residence trusts
Many clients established Qualified Personal Residence Trusts
(QPRTs) in years past.
Qualified Personal Residence Trusts
(QPRTs) allow for great discounts, but is it an appropriate strategy to use with the $5,000,000 exemption?
grantor retained anunity trusts, qualified personal residence trusts
, intentionally defective irrevocable trusts and family limited partnerships) still work in most situations.
ALTHOUGH QUALIFIED PERSONAL RESIDENCE TRUSTS
are less flexible than when they first were created, they still can provide attractive tax benefits to certain homeowners.
The first part of this two-part article, in the January 2001 issue, discussed five top estate planning techniques: use of lifetime gifts, insurance trusts, dynasty trusts, qualified personal residence trusts
and grantor retained annuity trusts (GNATs).
Observation: As rates continue to rise, qualified personal residence trusts
(QPRTs) and charitable remainder annuity trusts become favored over GRATs and CLATs.
In the September issue, Part II of this article will examine cases and rulings in myriad areas, including gifts of family limited partnership interests, charitable split-dollar insurance arrangements, qualified personal residence trusts
, valuation discounts and retirement planning.