White Paper

Types of Crummey Powers and Estate Planning

 
Crummey and Cristofani demonstrate two of the three varieties of Crummey powers: basic Crummey powers, naked Crummey powers and semi-naked Crummey powers. A basic Crummey power (in favor of a trust beneficiary) is given to a trust beneficiary who has an interest in the corpus of the trust. A naked Crummey power is a lapsing demand right on the part of a trust beneficiary without any corresponding interest in the corpus of the trust. A seminaked Crummey power is given to a beneficiary whose interest in the trust corpus, external to their Crummey power, is contingent upon the occurrence of some uncertain future event.

From the beginning, the Service has attempted to place limits on the expansion of the class of beneficiaries eligible to hold Crummey powers. Generally, the Service recognizes the validity of Crummey powers for beneficiaries who hold a current income interest or vested remainder interest in the trust, provided there is no pre-existing understanding between the grantor and the beneficiaries concerning the exercise of their withdrawal rights.

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

Todd Denison

Phelps Dunbar LLP

Agenda

Faculty

Todd Denison

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.

Sign Up Today

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.