In today's real estate market, a popular estate planning technique is to reduce the size of an estate by transferring a residence to a qualified personal residence trust
Some estate planners and commentators describe Qualified Personal Residence Trusts
(QPRTs) as a "can't miss" estate planning opportunity, while others consider them "having your cake and eating it too.
As an alternative, homeowners should consider the advantages of establishing a qualified personal residence trust
Roger and Cynthia Clary purchased the house from the Timothy Sambrano Qualified Personal Residence Trust
One such technique is the qualified personal residence trust
Elaborate provisions are contained in the proposed regulation released by the IRS on April 14, 1991, for a qualified personal residence trust
Two methods by which property can be transferred within a family to minimize estate taxes are use of a qualified personal residence trust
or a qualified terminable interest property trust.
Two of the more common instances in which this may arise may be with a grantor retained annuity trust or a qualified personal residence trust
The Service held that the trust holding the residence was a valid qualified personal residence trust
(QPRT) under Regs.
Cases, regulations and rulings on the following are discussed: use of deathbed and other family limited partnerships; qualified personal residence trust
final regulations; gift tax on the sale of a qualified terminable interest property remainder interest; and gift tax ramifications of gifts of nonvested, nonstatutory compensatory stock options.
These include the grantor retained annuity trust (GRAT), grantor retained unitrust (GRUT) personal residence trust (PRT) and the qualified personal residence trust
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.