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Trust Basis and Promissory Notes: During Life and At Death; 2025 Estate & Gift Tax Conference
Taxation Law Section
Credit(s):
0.75 Legal Specialization in Estate Planning; Trust & Probate Law
0.75 Legal Specialization in Taxation Law
0.75 Participatory MCLE Credits
In Rev. Rul. 2023-2, the IRS determined that §1014 does not apply to the assets in an IDGT upon its grantor’s death. However, not only do some commentators remain skeptical of the ruling, but in many ways the ruling does little more than to highlight the other mysteries involving grantor trust toggling, such as the basis regime that does apply on a grantor’s death and the common issue of promissory notes to or from an IDGT becoming recognized upon the grantor’s death. Indeed, many other ancillary matters remain unclear, including transactions involving a grantor trust and a third-party and the treatment of basis in a trust interest. Join this panel to benefit from the most exhaustive research into these issues yet conducted by learning the most likely answers to many of these mysteries.
0.75 Legal Specialization in Estate Planning; Trust & Probate Law
0.75 Legal Specialization in Taxation Law
0.75 Participatory MCLE Credits
All
Standard
Non-Member
$48.75
CLA Member
$33.75
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