Spurgeon, Federal Taxation of Trusts, Grantors
and BENEFICIARIES [paragraph][paragraph] 4.
As an unfunded trust, the grantor
will normally make annual gilts to the trust so that it can pay the insurance premiums.
Although the grantor
cannot change the beneficiaries of the ILIT, the trust agreement could give the grantor
the right to cancel or modify a beneficiary's annual withdrawal rights.
then gifts the premiums to the third-party owner when they are due.
As a result, subsequent creditors, purchasers, or lenders of the grantor
may assert their claims against the property.
The complex ownership arrangement designed by the grantors
in this ruling created a fragile environment for the S election, with several possible potential traps that should be anticipated and avoided.
This often occurs where the grantor
desires to spread the beneficial ownership among a number of individuals.
For several years, there have been questions about the gift and estate tax consequences of the payment and reimbursement of the income tax liability arising from a grantor
"seeds" an IDIT with cash or property that creates a taxable gift.
Step 3: The grantors
of the trust receive income each year from each trust.
Contrary to current products designed to reduce payment delinquency, as the WebTeck(TM) is totally transparent to users and easy to use for credit grantors
, it can address the low as well as the high end portion of the Buy Here, Pay Here (BHPH) market segment further expanding potential sales.
organization making grants is under increased scrutiny to document its relationships to foreign grantees, and can be penalized if it does not.