Agenda
The use of trusts to transfer, preserve and protect wealth can implicate the Generation Skipping Transfer Tax (“GST”) (IRC §§ 2601 et. seq.). A comprehensive discussion of the GST is beyond the scope of these materials but a brief treatment of the GST implications of a lapse of Crummey powers is included here. The GST consequences of a lapse of a Crummey power depend on whether the lapse is treated as a release. There are two deemed consequences for GST purposes when a lapse of a Crummey power is treated as a release: 1.) a deemed distribution/transfer by the trust to the holder of the Crummey power; and 2.) a deemed transfer back to the trust by the power holder. Generally, the deemed distribution to the Crummey power holder is treated as a taxable distribution to the power holder subjecting such person to paying the GST tax due.Download this white paper to continue reading …
Todd L. Denison is a Partner with Phelps Dunbar LLP. He represents individuals and business entities in the areas of business transactions and operations, partnership and corporate taxation, real and personal property transactions and trust and estates. Mr. Denison is a frequent speaker and has several publications.
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]
All of your training, right here at Lorman.
Pay once and get a full year of unlimited training in any format, any time!
- Live Webinars
- OnDemand Webinars
- MP3 Downloads
- Course Manuals
- Audio Recordings*
- Executive Reports
- White Papers and Articles
- Sponsored Live Webinars
Additional benefits include:
- State Specific Credit Tracker
- Members Only Newsletter
- All-Access Pass Course Concierge
* For audio recordings you only pay shipping
Questions? Call 877-296-2169 to speak with a real person.
Thank You!
Download White PaperMore Program Information
Access to all training products $699/year
Unlimited Lorman Training
With the All-Access Pass there is no guessing what you will need for your yearly training budget. $699 will cover all of your training needs for an entire year!
Easy Registrations
Once you purchase your All-Access Pass you will never be any further than one-click away from attending any Lorman training course.
Invest in Yourself
You haven't gotten to where you are professionally by luck alone; it's taken a lot of hard work and training. Invest in yourself with the All-Access Pass.
