Trustees managing taxes? Use the 65 day rule

Trustees trying to manage the tax burden of a complex trust should be familiar with the 663(b) election, also known as the 65 day rule. Making this election can often help to lower the overall tax burden of the trust and its individual beneficiaries. Trusts pay tax at the highest tax rate of 39.6% when …

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Step Transaction Doctrine

A recent case in the federal district court highlights the need to have some time elapse between the date of formation and funding of an FLP or FLLC and the date of gifting of interests in the FLP/FLLC. In Heckerman v U.S., the taxpayers (David and Susan Heckerman) took the following steps in gifting of …

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