SolidX Bitcoin Trust, a proposal by SolidX Management LLC, a subsidiary of blockchain technology company SolidX Partners Inc., is also structured
as a grantor trust.
• the Trust fails to qualify for treatment, or ceases to be treated,
as a grantor trust for US federal income tax purposes, and the Trustee receives notice from the Sponsor that the Sponsor determines that, because of that tax treatment or change in tax treatment, termination of the Trust is advisable;
the Trust fails to qualify for treatment, or ceases to be treated,
as a grantor trust for US federal income tax purposes, and the Trustee receives notice from the Sponsor that, because of that tax treatment or change in tax treatment, termination of the Trust is advisable;
The ILIT should be drafted
as a grantor trust, which allows the sale to skirt both the three - year rule and any transfer for value issues.
The ILIT should be drafted
as a grantor trust, which allows the sale to skirt both the three - year rule and any transfer for value issues.
Not exact matches
«One potential issue with a
grantor trust structure [for a bitcoin ETF] is that assets within a
grantor trust structure have historically had to be physical assets
as well
as homogenized.
The Winklevoss twins propose to structure their bitcoin ETF
as a «
grantor trust.»
The
Trust is classified as a «grantor trust» for US federal income tax purp
Trust is classified
as a «
grantor trust» for US federal income tax purp
trust» for US federal income tax purposes.
These shares do not include 1,213,435 shares, valued at approximately $ 247,856,233 on March 20, 2015, that Mr. Pearson,
as the
grantor, previously contributed to the J. Michael Pearson
grantor retained annuity
trust, for which he is not the trustee and in which he has no pecuniary interest; however, the shares in this
trust remain subject to the same selling restrictions
as applicable to Mr. Pearson.
Revocable
trusts, sometimes referred to
as revocable living
trusts, living
trusts, or inter vivos
trusts, refers to
trusts that the
grantor can amend at any time.
As icing on the cake, an IDGT may be set up so that the
grantor authorizes the use of
trust income to pay life insurance premiums on the
grantor's or the
grantor's spouse's life.
A family living
trust (typically husband and wife) or a joint
trust with two
grantors can be used to shift assets between the spouses upon death
as a way to most effectively use the deceased spouse's exemption amount.
Another key distinction for CRATs, CLATs and CRUTs, CLUTs, is whether the
trust will be treated
as a
grantor or non-
grantor trusts.
Transfers to a revocable (or
grantor)
trust, which acts
as the agent of the same individual, are not taxable nor reportable.
If they're minors (under age 18), you should probably establish
grantor trusts for each of them and name the
trusts as the beneficiaries.
For example,
grantor trusts can hold an interest in a physical commodity such
as gold, while limited partnerships are more likely to be used for commodity - centric ETFs with exposure to futures contracts.
As such, it is a leap of faith to expect individual investors to easily comprehend the differences between exchange - traded funds, exchange - traded notes, unit investment
trusts, and
grantor trusts.
The AFR is useful for tax concepts such
as Original Issue Discount (when issuers sell low - interest or no - interest bonds or loans at less than face value, attempting to recharacterize interest income
as return of principal), various
grantor trusts (e.g. GRATs), and so forth.
Index ETFs can be set up
as either
grantor trusts, unit investment
trusts (UITs) or open - ended mutual funds, and will subsequently have some different regulatory guidelines.
Two asset protection benefits are, one, that an irrevocable
trust may be set up for the employee to own the policy, such
as an irrevocable life insurance
trust OR another type of
grantor trust, and this can assure that the policy will not be included in the employee's taxable estate for split dollar estate planning purposes.
Publicly traded
grantor trusts, such
as Merrill Lynch's HOLDRs securities, are sometimes considered to be ETFs, although they lack many of the characteristics of other ETFs.
Grantor trusts are also often used for various strategies such
as using intentionally defective
grantor trusts with a «gift and note» concept in order to gain income and estate tax savings.
A nonresident
trust that is required to file a federal return, including a
grantor trust, with gross income (
as defined in IRC Section 61 (a)-RRB- from Idaho sources of $ 100 or more for the current tax year
A resident
trust that is required to file a federal return, including a
grantor trust, with gross income (
as defined in IRC Section 61 (a)-RRB- of $ 100 or more for the current tax year
We design estate plans that include revocable and irrevocable
trusts, including insurance
trusts, generation skipping and dynasty
trusts,
grantor retained annuity
trusts, intentionally defective
grantor trusts, and charitable
trusts as well
as family limited liability companies and family limited partnerships, and private foundations.
Ms. Yazdchi's experience also includes drafting and implementing revocable
trusts, financial and healthcare powers of attorney, more complex
trust instruments such
as irrevocable intentionally defective
grantor trusts (IDGTs), and all aspects of
trust and probate administration.
Mr. Hafen's practice includes advice regarding sophisticated tax, estate, asset protection, and business planning strategies, including the preparation of documents such
as wills, living
trusts, durable powers of attorney, healthcare directives, asset protection
trusts, irrevocable life insurance
trusts, gift programs,
grantor retained annuity
trusts, education
trusts, family limited partnerships and limited liability companies, generation - skipping transfers, charitable giving, charitable remainder
trusts, private foundations, property agreements, and prenuptial and postnuptial agreements.
Although there are many advantages to setting up an irrevocable
trust, they aren't quite
as common
as revocable
trusts simply because the
grantor loses control and rights to any assets transferred to the
trust.
A revocable
trust, also known
as a living
trust, allows the
grantor the right to alter, change, modify, or revoke it entirely.
An insurance
trust is an irrevocable
trust set up with a life insurance policy
as the asset, allowing the
grantor of the policy to exempt asset away from his or her taxable estate.
Two asset protection benefits are, one, that an irrevocable
trust may be set up for the employee to own the policy, such
as an irrevocable life insurance
trust OR another type of
grantor trust, and this can assure that the policy will not be included in the employee's taxable estate for split dollar estate planning purposes.
If there is a question about the
grantor being able to obtain coverage and you want to verify insurability before paying the expense of having a
trust drafted, have the
grantor apply for coverage and list the owner
as a
trust to be named.