|
Selections from Table
of Contents: Reference Edition |
| Alternatives
to the CRT |
Dispositions
of the Income Interest |
| Definition of
a CRT |
Class of Beneficiaries |
| When is a CRT
Necessary? |
Unborn Children
/ Future Spouses |
| When to Consider
a Nonqualified CRT |
Sprinkling Authority |
| Charitable Remainder
Annuity Trusts |
Donor's Estate
as Successor Beneficiary |
| Charitable Remainder
Unitrusts |
Payout Periods |
| Net Income Limitation |
Diminish / Revoke
Income Interest |
| "Flip" Unitrusts |
Payout Rates
/ 5% Probability Test / Contingencies |
| Definition of
"Income" / Make-up Account as Liability |
Charity's Remainder
Interest |
| Multiple Trusts
/ Grantors |
Designating
the Charity |
| Grantor Trust
Rules |
Financing the
Remainderman's Activities |
| Invasion of
Trust Prohibited |
Sales of the
Remainder Interest |
| Selecting the
Trustee |
Charity Shares
in the Income Interest |
| Exempt Status
of the Trust |
Income Tax Charitable
Deduction / Income Limitations |
| Trust Becomes
a Private Foundation |
Gift of the
Income Interest to Charity |
| Inter Vivos
v. Testamentary Transfers |
Income Stream
and Taxes Thereon |
| CRT / QTIP Considerations |
Ordinary Income
/ Capital Gains, etc. |
| CRTs Avoid Capital
Loss Limitation |
Character and
Timing of Income |
| Restrictions
on Trust Investments |
Deferral of
Income |
| Income in Respect
of a Decedent |
Retirement Planning |
| Avoiding Sale
Treatment to Donor |
Income Shifting |
| Transferring
Liabilities to CRT |
Investment of
Tax Savings / Life Insurance |
| Partial Sales |
Passive Activity
Rules |
| CRTs that Co-Own
Property |
Gift Tax / Estate
Tax / Generation-Skipping |
| Corporations
and Partnerships |
Qualification
of Testamentary Trusts |
| Valuation Issues |
Inclusion in
Grantor's / Beneficiary's Estate |
| Avoiding Dividend
Treatment to the Donor |
Excise Taxes
/ Self-Dealing and Other |
| Compensation
and Stock Option Issues |
Transfers of
Partial Interests to CRTs |
| Permissible
Recipients / Taxing Authorities / Creditors |
Administrative
Costs / Appraisals |
| Payments "For
the Use of" a Beneficiary |
Profiles of
Potential Candidates |
| Payments to
Beneficiary's Estate |
Considerations
Affecting the Alien |
| Payments of
Interest |
Donative Intent |
