Session 2: A Potpourri of Hot Topics Concerning the Income Taxation of Trusts and Estates and Their Beneficiaries

Take the chair lift to the summit of Subchapter J and navigate through the fresh powder of the basis rules and tax issues for charitable and international trusts, as well as estates and trusts holding business interests.

Topics include charitable tax issues (including the 642(c) deduction, split interest trusts, UBTI and nuances of CLATs), and international tax issues (including the taxation of foreign trusts with US beneficiaries, and the taxation of distributions from US trusts with US citizen beneficiaries living abroad). We will then segue over to business-related matters (including QSSTs and ESBTS, the relationship between passthrough entities and trusts, and the consequences of termination including with respect to carryovers). Finally, we’ll conclude with a discussion of things that shouldn’t be subject to income tax but sometimes are (such as gifts and forgiveness of indebtedness) and basis issues (including adjustments at death, equitable recoupment, the basis consistency rules, and the tax basis of inherited S corporation stock).

Speakers: Mickey R. Davis, Jermiah W. Doyle, Michael C. Gerson