Assets of foreign grantor trust not includible in grantor's U.S. gross estate.: An article from: The Tax Adviser

by William J. Zink

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This digital document is an article from The Tax Adviser, published by American Institute of CPA's on February 1, 1994. The length of the article is 940 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.

From the supplier: An IRS ruling addressed the tax treatment of the formation and management of an off-shore trust with a US partnership as its corpus and US beneficiaries. The IRS found, consistent with the taxpayers' wishes, that the transfer of limited partnership interests by the settlers to the trust were taxable gifts. The partnership interests were not includible for estate tax purposes as the trust was a grantor trust and the portion of the trust owned by each settler would not be so owned at death.

Citation Details
Title: Assets of foreign grantor trust not includible in grantor's U.S. gross estate.
Author: William J. Zink
Publication: The Tax Adviser (Magazine/Journal)
Date: February 1, 1994
Publisher: American Institute of CPA's
Volume: 25 Issue: n2 Page: 84(2)

Distributed by Thomson Gale

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