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.
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
TRA 86 instituted a Generation Skipping Transfer
Tax (GST Tax) upon transfers to or for the benefit of persons two or more generations below that of the grantor (referred to as skip persons).
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.
1975 of the 106th Congress (The Generation Skipping Transfer
Tax Amendments Act of 1999), and the House, Senate (modified version), and conference agreement bills of H.