The Irrevocable Grantor Trust – An Overview

"A 'grantor' trust is a trust that contains certain provisions set forth in the Internal Revenue Code, which defines these types of trusts. Grantor trusts are sometimes referred to as 'intentionally defective irrevocable grantor trusts' or 'IDIGTs.' The 'defective' nature of these trusts results from the fact that while the trusts are irrevocable and are treated as separate from the grantor or creator for estate tax purposes, the trusts have specific provisions that require their income to be taxed to the grantor. With a carefully drafted irrevocable grantor trust, the income is imputed to you as the creator of the trust, but the trust assets are not included in your estate for estate tax purposes..."

Preferred Family Limited Partnerships in Multi-Generational Estate Planning

"Prior to the enactment of Internal Revenue Code (IRC) §2701, estate planners often designed entity structures that effectively freezed the value of their clients' estates for purposes of transferring assets between members of the same family. A typical example of an 'estate freeze' worked like this: a father owns a business valued at ten million dollars and wants his daughter, who has been working for him, to take over the company as he steps away from dayto- day management of the business operations..."

Family Limited Partnership

"The term 'Family Limited Partnership' is the common name for a limited partnership created primarily to shift ownership of assets, and sometimes income, to family members. The Family Limited Partnership is an established estate-planning tool that, when properly established, can:

• Maintain 100‰ control of the assets in the partnership;
• Immunize assets from future creditors;
• Allow income from assets to be split among family members in lower tax brackets;
• Create a significant reduction in federal estate and gift taxation;
• Make annual gifting and lifetime gifting significantly easier.

Pouring Old Wine into New Bottles - Using Traditional Estate Planning Tools in Untraditional Ways

"Many estate planners have concluded that the famous proclamation from the Book of Ecclesiastes that "there is no new thing under the sun" is applicable to their planning strategies. The conventional wisdom provides that there are well known legal strategies and financial tools that have been thoroughly explored and that may be appropriate in particular, predicable circumstances..."

Introduction to the Strategy

"Grantor Retained Income Trusts (GRITs) had historically been a device to transfer assets to the next generation with minimum use of a person's unified credit through the use of valuation discounts. In 1990 Congress passed legislation which curtailed many past uses of these devices. However, the 1990 tax law carved out a specific exception – the Qualified Personal Residence Trust ("QPRT")..."