In that ruling, the Service relied on Crummey to find that the settlor was entitled to annual gift exclusions for all persons with withdrawal rights, including contingent beneficiaries
Related parties for purposes of the depreciable property installment sale rule are limited to individuals and corporations or partnerships in which they own more than 50%, an individual and any trust in which he and his spouse are more than remote contingent beneficiaries
, and two or more partnerships in which the same persons own, directly or indirectly, more than 50% of the capital or profits interests.
Unless withdrawal privileges for contingent beneficiaries
are structured in a manner similar to that of Cristofani or Letter Ruling 9030005, the IRS may challenge future attempts to use annual exclusions for contingent interests.
Naming contingent beneficiaries
One or more persons/charities/ Contingent beneficiaries
may be institutions may be named to named (to receive funds after any receive any remaining trust funds required Medicaid payback).
Beneficiary designations should be part of a consistent review process, and this is true for primary beneficiaries and contingent beneficiaries
," says Cambier.
In addition, the IRS will likely challenge exclusions for powers held by contingent beneficiaries
Ensure both primary and contingent beneficiaries
are assigned to your retirement accounts.
Letting clients name minor children outright as primary or contingent beneficiaries
of life insurance or retirement plans.
To avoid having the state design an estate plan for you, name contingent beneficiaries
in your will, living trust, life insurance policy, retirement plans and other important documents that require a beneficiary designation.
Servicemembers may designate principal and contingent beneficiaries
In this scenario, even if the beneficiary spouse predeceases the IRA owner, the children are designated properly as the contingent beneficiaries
and will be able to take distributions based upon their individual life expectancies.
Your surviving spouse also has the option to disclaim the assets, resulting in the assets going to other named primary or contingent beneficiaries