Review an analysis of the Crummey v. Commissioner case.
The Crummey case turned on an interpretation of the definitions of future interest and present interest. The taxpayers in Crummey created a trust for the benefit of their four grandchildren. The operative feature in the trust instrument provided that each of the four beneficiaries of the trust could demand, at any time up until December 31 of a given year, up to $4,000 or the amount transferred into the trust during such year, whichever was less. What distinguished the Crummey case from other cases was that the demand power granted to the beneficiaries did not continue for the life of the trust, but rather lapsed at the end of each year it was given. This white paper reviews how the decision in Crummey v. Commissioner directly addressed a fundamental flaw in tax policy.
Agenda
Faculty
Todd Denison
Phelps Dunbar LLP
- Partner with Phelps Dunbar LLP
- Practice focuses on business and tax law
- Counsels corporate and individual clients in various facets of their business operations, including: corporations and partnerships, employee stock ownership plans (ESOP), general tax advices, and trust and estates/estate planning
- Advises closely held companies nationwide on ESOP transactions, from feasibility studies to plan development, document drafting, and financial structuring, while collaborating with banks and benefits counsel to ensure compliance and optimal outcome
- Clients include a regional engineering firm, national advertising agency, regional construction firm, regional stone and interior design firm, and numerous family-owned businesses operating locally, regionally, and internationally
- Frequent speaker and has several publications
- Member of numerous professional and civic organizations
- Achieved the highest rating with Martindale-Hubbell Law Directory
- Mid-South Super Lawyers Rising Stars list, Super Lawyers (2010-2014), Business Organizations (including LLCs and Partnerships) (2019-2025), Tax Law (2018-2025), Trusts and Estates (2018-2025), The Best Lawyers in America
- LL.M. Degree, New York University School of Law; J.D. Degree, University of Montana School of Law; M.A. and B.A. Degrees, University of Montana
- Can be contacted at 251-441-8206 or [email protected]
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