Income Taxation of Fiduciaries and Beneficiaries 2007 (Two Volume Set)

by Byrle M. Abbin

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Income Taxation of Fiduciaries and Beneficiaries provides step-by-step guidance on the taxation of fiduciary income. This comprehensive guide for practitioners advising fiduciaries and beneficiaries in federal and state income tax matters covers the broad range of complex issues from charitable remainder trusts to nexus rules and their effect. Providing expert practical advice, Income Taxation of Fiduciaries and Beneficiaries helps the practitioner obtain the most advantageous outcomes for his/her fiduciary and beneficiary clients. Key feature: 35 case studies with filled-in forms 1041 and accompanying documents. Highlights of 2007 edition include: Â· Consideration of the many private letter rulings granted to CRTs allowing reformation: (1) to qualify under IRC Â§664; (2) to correct scrivener s error on trust terms; Â· Analysis of the recognition by the IRS of the trustee s ability to sprinkle/spray income between individual and non individual CRT distributees in conformance with Treasury regulations; Â· Coverage of the fact that an S corporation can form a CRT, be the distributee, and obtain charitable deduction through contribution of built-in gain property, and yet defer recognition of such income; Â· Discussion of the impact of the new 100% excise tax on unrelated business taxable income realized by a CRT; Â· Further interpretation of total return trust treatment under RUPIA and treatment of distributions including tax reimbursements from a flow through entity; Â· Discussion of the impact of the Rudkin case on reporting of deduction for investment advisory fees, i.e. the impact of the 2% non-deductible portion under IRC Â§67(e); Â· Analysis of NOL and capital loss rules as applied to trusts and estates; Â· Coverage of nongrantor trust status for trusts that nonetheless result in incomplete gifts due to retained power of appointment; Â· Consideration of the use of trust partitioning followed by merger of trusts to effect a tax-free exchange of partnership interests that otherwise is unattainable; and Â· Discussion of the benefit of a grantor CLAT in determining source of charitable deduction as any property, not just from gross income.

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