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I already answered some of my other questions but I am really stuck on these 5. I only have to choose 3 of them. Any help would be appreciated.
Question 1
Jack Harris has come to you for advice concerning the establishment of a Qualified Personal Residence Trust that he read about in an article in a local newspaper. Jack is 48 years of age in good health. He has two children, ages 16 and 21, and is a widower. He owns a principal residence that cost him $445,000 and is worth $1,100,000. The balance of his estate is approximately $12 million in value.
You are to advise him about the establishment of a QPRT, highlighting the benefits and detriments.
Question 2
Discuss each of the following issues briefly:
a. Describe the significance and use of Crummey powers in gift giving and estate planning. Your discussion should also focus on the Christofani case and its impact.
b. Discuss the impact of gifts made during lifetime on the estate tax computation when a taxpayer dies.
Question 6
Define and discuss the role of the Generation Skipping Transfer Tax. Include in your discussion “skip persons” giving examples, and how the tax is triggered, and identify the party responsible for the payment of the tax.
Your discussion should include the exemption available and how it should be allocated to any GST transaction.
Question 7
Fully discuss the sale to an “intentionally defective grantor trust” focusing on what it is, how it is treated for income tax, gift tax and estate tax purposes. Discuss under what situations it would be used and explain any non-tax issues that it presents.
Your discussion should include what happens if the seller dies during the term of the note issued on the sale, and what happens if he/she outlives the note. Make certain that you include a discussion of “seed money.”
Question 9
Fully discuss the affect of portability on credit shelter by pass planning. Your discussion should include a complete discussion of the portability rules as well as the credit shelter planning technique.
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