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- Title
STEPPING UP BASIS IN LIVING TAXPAYER ASSETS WITH UPSTREAM WEALTH TRANSFERS THROUGH INTENTIONALLY DEFECTIVE GRANTOR TRUSTS.
- Authors
SCHAUM, MICHAEL J.
- Abstract
The article argues that an Intentionally Defective Grantor Trust (IDGT) structured as an upstream gift is a legal mechanism to increase basis in appreciated assets and allows high net-worth individuals to legally avoid capital gains taxes by stepping basis up in their own appreciated assets. Topics include the tax and estate planning principles underlying the legality of the wealth transfer and the absence of guidance from the U.S. Internal Revenue Service on the legality of trust structures.
- Subjects
GRANTOR trusts; HIGH net worth individuals; CAPITAL gains tax; TAX planning; ESTATE planning; UNITED States. Internal Revenue Service
- Publication
St. Thomas Law Review, 2023, Vol 36, Issue 1, p80
- ISSN
1065-318X
- Publication type
Article