Re: Is the Credit Shelter Trust a Grantor Trust?

I am still working on the 679 possibility. I'm curious why

> no one seems to want to look seriously at it. It's probably > unfamiliar to most people, but I still think it will work > very well. Look at the definition of "foreign"trust--sec. > 301.7701-7. It has nothing to do with moving money to a > foreign country, and thetrustincome is taxable to the > "transferor". Furthermore, I don't mind if we have to > recognize a gain per sec. 684, since that's what we want to > do anyway.

I suspect the reason you are not getting any takers is because you are asking for answers to a fairly sophisticated tx situation, and one that does not pop up every day. That means that someone is going to have to do some research to help you. There are many extremely kind people on this forum, all of who are volunteering their services in answering questions. Answering your question is going to require a significant amount of work and it will be to answer a question that is not likely to come up again in most professionals' practices, so there's not much incentive to look into it for free. I'd strongly recommend that you seek out a tax attorney, or CPA, or EA who has some experience with estate planning and with foreign trust issues if you'd like to pursue this further.

--Chris

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cballard
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