resident taxpayer who was the income beneficiary of a series of trusts was permitted to avoid gift and generation skipping transfer
("GST") taxes through disclaiming his interests in the trusts even though he had received distributions of income in the past.
The generation skipping transfer
tax is applied to transfers made to generations two or more levels younger than the taxpayer, such as grandchildren.
His specializations include trust and estate planning, particularly generation skipping transfer
taxes and business succession planning; income tax planning and consulting; stock option planning; cash flow and risk management planning; retirement planning; education planning and charitable giving.
In addition, the bill rcunifies the gift, estate and Generation Skipping Transfer
tax exemptions and makes the lifetime exemption portable between spouses, such that if it is not used by the first spouse to die, it would be available to the survivor.
On P's Form 706, United States Estate (and Generation Skipping Transfer
) Tax Return, the value of the remaining prize installments was discounted to account for Connecticut's restrictions on Lotto winnings: (1) all prizes in excess of $1 million were payable in 20 equal annual payments, which could not be accelerated and (2) winners were forbidden from assigning or transferring their right to future installments to third parties.
Under IRC section 7491, in any court proceeding the IRS has the burden of proof with respect to any factual issue relevant to determining a taxpayer's liability for any income, self-employment, gift, estate and generation skipping transfer
GENERATION SKIPPING TRANSFER
TAX--FILING REQUIREMENTS FOR THIS TAX YEAR
In this private letter ruling, the IRS allowed an extension of time for the executor of an estate to correct the decedent's failure to properly plan for generation skipping transfer
("GST") taxes when he created a QTIP trust to pass assets to his beneficiaries.
This article examines recent developments in estate, trust, gift and generation skipping transfer
Congress included the proposal the AICPA helped develop to modify the generation skipping transfer
tax in its bill to repeal estate taxes.
Since the IRS maintains separate records for income, gift, estate and generation skipping transfer
taxes, the notification should say what type of tax is affected by the address change.
The Warners have a well-designed estate plan and are confident that their children will be provided for after their deaths, but they have been reading about increased exemptions for generation skipping transfer
taxes that are likely to expire at the end of 2012.