An Intentionally Defective Grantor Trust (“IDGT”) is an irrevocable trust created so that the assets of the trust are attributable to the grantor for federal income tax purposes, but not for gift, estate, or generation skipping transfer tax. The “defect” is that the grantor reports all of the income, deductions, and credits associated to the … Continued
Recently, I worked on a case involving an individual who wanted to put his $90,000 IRA into a Self-Settled (d)(4)(A) Trust. Even though I could get the IRA transferred into a tax-deferred annuity owned by the trust, there was a question as to whether the transaction involved a taxable event. To eliminate the question, the … Continued
The income taxation of annuity contracts is governed by Section 72 of the Internal Revenue Code (“IRC”). In the 1980s, as a result of the tax simplification and reform measures, the code section went through extensive revisions. The legislation was intended to encourage the use of tax-deferred annuity contracts as long-term retirement savings vehicles. … Continued