Wealth Strategies Journal

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Tag: Lee

The IRS Clarifies the Potential Impact of the GST on Irrevocable Trusts and Proposed Codicils

On February 25, 2014, the IRS published  PLR 201425007  which addressed the potential effects of the Generation-Skipping Transfer Tax (GST) on Irrevocable Trusts and successor trusts. The Settlor executed a Trust Agreement prior to September 25, 1985 which created the Irrevocable Trust in question.  The trust document defines “primary life beneficiary” … Continue reading

Variable Payment Annuities May Produce Includable Gross Income Only to the Extent Payments Exceed Calculated Contract Payments

A stock life insurance company, properly organized and operated under applicable state law and qualifying as a life insurance company under IRC Sec. 816(a), requested two rulings in regards to a new term certain annuity option with variable payments (the “New Annuity Option”) with non-qualified deferred variable annuity contracts (the … Continue reading

IRC Sec. 465’s “At-risk” Provision is Inapplicable at the Partnership Level

Reiterating the holding in Hambrose Leasing v. Commissioner, 99 T.C. 298, 310 (1992), the IRS published PLR 201424022 stating that the IRC Sec. 465 “at-risk” provisions do not apply at the partnership level. Instead, only after the tax implications are passed through to the individual will the court be able … Continue reading