WebSection 675(4) provides, in pertinent part, that the grantor shall be treated as the owner of any portion of a trust in respect of which a power of administration is exercisable in a nonfiduciary capacity by any person without the approval or consent of any person in a fiduciary capacity. For purposes of this paragraph, the term “power of WebOct 12, 2016 · Similarly, a so-called “substitution power” under IRC Section 675 (4) (C) – which allows the grantor to swap personal assets with trust assets, as long as the substitute asset has equivalent value – also causes the trust’s income to be treated as the grantor’s for income tax purposes, but usually will not cause the assets to be included for …
Trust planning opportunities available with swap powers - The Tax …
WebSep 1, 2024 · When exercising swap powers under Sec. 675, the trustee must be under a fiduciary obligation to ensure that the assets substituted or swapped are of equivalent value (see Rev. Rul. 2008 - 22 ). The transaction may not leave beneficiaries of the trust in a better or worse economic position. WebMar 24, 2010 · The trust instrument could provide that the grantor retains the right to reacquire trust corpus by substituting property of an equivalent value (a “grantor trust” power under IRC Section... the pump okc bar
Using GRATs Prior to the Effective Date of the 2704 Proposed ...
WebAug 16, 2016 · The client might address this risk in part through a swap power (power of substitution under IRC Section 675(4)(C)) to capture and immunize the volatility in a GRAT. The grantor could exercise the ... WebSection 675 IAC 14-4.4-227 - Appendix B; sizing of venting systems serving appliances equipped with draft hoods, Category I appliances, and appliances listed for use with Type B vent; Section 675 IAC 14-4.4-228 - Appendix C; exit terminals of mechanical draft and direct-vent venting systems WebDec 17, 2015 · This is commonly referred to as a “swap” power. The power to “reacquire the trust corpus by substituting other property of equivalent value” causes the trust to be treated as a grantor trust for income tax … the pump partners