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IRC Section 678 and Beneficiary Deemed Owner Trusts



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Please join Ed Morrow in his 60 minute LISI webinar tilted "IRC Section 678 and Beneficiary Deemed Owner Trusts." Taxpayers are increasingly focused on the income tax aspects of their estate plan as much, if not more, than the estate tax aspects. One challenge in minimizing income tax is the complexity and occasional unfairness of the fiduciary income tax system. This webinar will explore how settlors can avoid the application of these fiduciary income tax rules by including a power that forces the beneficiary to be deemed the owner for income tax purposes. Most importantly, this can be accomplished with a power to withdraw the taxable income without the more drastic and far-reaching power to withdraw the entire corpus itself.

Ed will review when such a design might be appropriate and the important income tax rules of powers of withdrawal over income and/or corpus as well as the estate/gift tax and asset protection impact they may have (and how to eliminate it).

His presentation will also address:

· IRC Section 678 and the grantor trust "portion" rules;

· Contrast powers over only taxable income v. powers over a portion or the entire principal;

· Comparisons of non-grantor trust scheme v. grantor trust scheme – including often overlooked income tax savings of using a beneficiary deemed owner trust;

· Estate/gift tax effect of withdrawal powers and lapses under IRC 2041/2514;

· Effect of withdrawal powers on spousal elective share, creditor protection;

· Effect of lapses on income tax, spousal elective share and asset protection;

· Techniques to limit or eliminate negative asset protection and/or gift/estate tax exposure;

· Contrasting with BDITs (beneficiary defective inheritor’s trusts) and general power of appointment marital trusts, which involve withdrawal powers over corpus rather than income;

· Coordinating with OBIT (optimal basis increase trust) clauses to ensure a step up and avoid a step down in basis on the primary beneficiary’s death.

· Coordinating and understanding the effect of concurrent use of trustee distribution/spray powers or lifetime limited powers of appointment

· And much more!




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Edwin Morrow, J.D., LL.M., MBA, CFP®, CM&AA® is a manager of Wealth Strategies at Key Private Bank.  As one of Key’s national wealth specialists, Ed works with local Key Private Bank financial advisory and trust teams nationwide.  He is also national manager of wealth strategies communications for the private bank.  He assists with in-depth reviews of high net worth clients’ estate, trust, asset protection and tax planning in order to better preserve, protect and transfer their wealth in a tax efficient manner.  Ed has been with Key since 2005.

He was previously in private law practice in Cincinnati, Ohio, concentrating in taxation, probate, estate and business planning.  Other experience includes drafting court opinions for the U.S. District Court of Portland, Oregon as a law clerk.

Education:

  • Bachelor of Arts (B.A.), History, Stetson University
  • Juris Doctorate (J.D.), Northwestern School of Law at Lewis & Clark College
  • Masters of Law (LL.M.) in Tax Law, Capital University Law School
  • Masters of Business Administration (MBA), Xavier University

Professional Accreditations:

  • Licensed to practice in all Ohio courts, U.S. District Court of Southern Ohio and U.S. Tax Court
  • Board Certified Specialist  through Ohio State Bar Association in Estate Planning, Trust and Probate Law
  • Certified Financial Planner (CFP®), Certified Merger and Acquisition Advisor (CM&AA®)
  • Non-Public Arbitrator for the Financial Industry Regulatory Authority (FINRA)


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