EstateBuyers.com

Grantor Trust Liabilities: An Income Tax Analysis

Date: Tuesday, November 18, 2014
Time: 6:00pm - 8:00pm
Location: Morton's The Steakhouse, West Palm Beach
Speaker: Jerry Hesch

Grantor Trust Liabilities: An Income Tax Analysis

by Jerome Hesch

The use of installment sales to grantor trusts and installment sales to non-grantor trusts, in both situations using irrevocable family trusts that are not includible in the grantor’s gross estate, are popular estate planning techniques, simultaneously involving three separate tax regimes: the income tax, the gift tax and the estate tax. 

The income tax issues relating to intra-family installment sales are complicated because the separate tax regimes have inevitable overlap, such as the step-up in basis at death under Section 1014, the treatment of income in respect of a decedent under Section 691, the treatment of gifts under Sections 102 and 1015 and the impact of liabilities under 
the income, gift and estate taxes. 

This program will address the income tax issues arising from specific situations.

About the Speaker:

Jerome M. Hesch is Of Counsel to Berger Singerman in Miami, Florida. He is the Director of the Notre Dame Tax and Estate Planning Institute, on the Tax Management Advisory Board, a Fellow of ACTEC, has published numerous articles, Tax Management Portfolios, and co-authored a law school casebook on Federal Income Taxation, now in its fourth edition.

He has presented papers for the University of Miami Heckerling Institute on Estate Planning, the University Of Southern California Tax Institute, the Southern Federal Tax Conference, and the New York University Institute on Federal Taxation, among others. He participated in several bar association projects, including the Drafting Committee for the Florida Revised Uniform Partnership Act and preparing the ABA’s comments on the IRS’s proposed private annuity regulations.

He received his B.A. and MBA from the University of Michigan and a J.D. from the University of Buffalo Law School. He was with the Office of Chief Counsel, Internal Revenue Service, in Washington, D.C. from 1970 to 1975, and was a full-time law professor from 1975 to 1994, teaching at the University of Miami School of Law and the Albany Law School, Union University. He is currently an adjunct professor of law, teaching courses at Florida International University Law School, the Graduate Program in Estate Planning at University of Miami and the online LL.M. program at Boston University School of Law. Having grown up in Buffalo, he remains a Buffalo Bills fan.

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