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
- Represents individuals and business entities in the areas of business transactions and operations, partnership and corporate taxation, real and personal property transactions, trusts and estates (including sophisticated estate) planning, charitable organizations (formation and operations), employee stock ownership plans and other qualified retirement plans, captive insurance, international transactions and taxation, tax controversies with the IRS, and elder law
- 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
- The Best Lawyers in America© (Woodward/White, Inc.), Business Organizations (including LLCs and Partnerships) in Mobile, 2019; Tax Law in Mobile, 2018-2019; Trusts and Estates in Mobile, 2018-2019
- 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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