Description
Understand how Crummey powers can be used to achieve your client’s estate planning goals.The decision in Crummey v. Commissioner directly addressed a fundamental flaw in tax policy the inability for parents to make annual gift tax exclusion gifts to their children in trust. After Crummey, parentdonors had a procedure by which to make such exclusion gifts. Indirectly, the Crummey decision spawned the rise of Crummey powers in estate planning, affording taxpayers and their advisors the ability to reduce methodically their gross estates and avoid estate and gift tax consequences. This topic will assist estate planners in understanding the development and practical application of Crummey powers, giving them a powerful tool to assist clients with achieving their estate planning goals.
Date: 2021-05-26 Start Time: End Time:
Learning Objectives
Overview: Crummey Powers
• Definition
• Generally
• Naked Crummey Powers
• Semi-Naked Crummey Powers
Historical Background
• Estate Tax
• Gift Tax
Annual Gift Tax Exclusion
• IRC § 2503(B)
The Key Issue
• Gift of a Present Interest
• Definition of a Present Interest
Crummey vs. Commissioner
• Analysis of Issues
• Case Legacy
Estate Planning Use of Crummey Powers
• Irrevocable Trusts
• Irrevocable Life Insurance Trusts
Expanding Crummey Powers • Cristofani v. Commissioner
• Analysis of Issues
• Use of Cristofani
Crummey Powers • a Usage Guide
• Typical Trust Language
• Examples
• Lapse Issues
• Hanging Powers
• Trustee Responsibilities
• Crummey Notice
• Crummey Waiver
• Problem Areas
• Parental Control Over a Minor Child’s Crummey Powers
• Informal Agreements for Waiver
CLE (Please check the Detailed Credit Information page for states that have already been approved) ,Additional credit may be available upon request. Contact Lorman at 866-352-9540 for further information.
Todd Denison-Phelps Dunbar LLP
