Section 645
Under Sec. 645, a qualified revocable trust may elect to be treated and taxed for income tax purposes as part of an estate (and not as a separate trust) for all tax years of the estate ending after the date of the decedent's death and before the applicable date described in Sec. 645(b)(2).
Section 645 Headlines
The Medicaid Trust
The cost of long-term health care continues to spiral and insurance companies continue to cover fewer and fewer long-term needs. As a result, it's important...
QPRTs Can Be A Good Deal Now
It seems counterintuitive, but qualified personal residence trusts (QPRTs) can make a lot of sense now...
As the Hearse Pulls Away
During the course of an estate's administration, a personal representative performs four basic functions: (1) marshals assets; (2) determines and raises...
The 505 Fix
There can be serious tensions with beneficiaries when a trustee is required to distribute all of the trust's income currently (meaning, it's a mandatory...
The Thrill of Trust Funding
Many professionals view the funding of trusts as insignificant and easily accomplished particularly when there's a surviving spouse and no estate tax...
Charitable Deductions For Non-Grantor Trusts
The general tax rule is that trusts compute their income and deductions as if they were individuals.1 Probably the most significant exception to this...
Tax Law Update
David A. Handler, partner in the Chicago office of Kirkland & Ellis LLP, reports: A citizen of a U.S. possession is not a U.S. citizen for estate-tax...
Inheriting from Abroad
Over the years, planners have found several techniques useful in helping non-U.S. families pass wealth to the next generation: offshore personal investment...
Post-Death Income Taxes
Sophisticated estate plans generally include certain types of family entities, such as family limited partnerships (FLPs), family trusts or combinations...
IRC Section 645 Is Your Friend
You've got a friend, or at least an ally, in Internal Revenue Code Section 645. Advisors don't often use the words and in the same sentence. But Section...
