Emerich of Farr, Farr, Emerich, Sifrit, Hackett & Curr, P.A., Punta Gorda, who provided the material on duties of closing agents and the idea for the 98-year lease approach to preserving the SOH cap upon termination of a QPRT
retained terns, as well as other helpfull guidance in this article's preparation.
The home must be the transferor's personal residence during the entire term of the QPRT
. (A vacation home may qualify.) If the transferor wishes to move during the duration of the trust (and assuming the trust's terms permit such actions), the trustee may sell the house and reinvest the proceeds in a new residence within two years with no adverse tax consequences.
Under Treasury Regulations section 25.2702-5(c), which creates the concept of a QPRT
, an individual would transfer title to either the apartment or the summer home to a QPRT
Author Jeffrey Baskies prepared two deeds and QPRTs
for Joe and Alma Stone, but did not represent a litigant in the substantive case.
With a federal estate tax exemption of more than $11 million, the significant estate tax savings that were anticipated when the QPRT
was created have disappeared.
Because the transfer of the personal residence to the QPRT
constitutes a gift, the grantor will want the value of the gift to be as low as possible.
Despite the requirement that the QPRT
must hold a residence, QPRT
status will not necessarily be terminated if the residence is sold during the QPRT
During the term of the QPRT
, grantors retain rent-free possession and enjoyment of the residence and pay all operating expenses as they did before the QPRT
The vulnerability showed in human cerebral neurons may be due to the fact that the neurons can take up exogenous QUIN but can only catabolize a small amount  since QPRT
is rapidly saturated.
The PRT and QPRT
are irrevocable inter vivos trust instruments designed to reduce the gift and estate tax costs involved in transferring personal residences to family members.
The initial transfer of the real estate to the QPRT
is a gift to the remainder beneficiaries that is valuedbased on the remainder interest in the property.
The qualified personal residence trust (QPRT
) uses that strategy and allows the homeowner to give away her home while retaining the right to occupy it for life.