This article summarizes a stock option strategy within a Grantor Retained Annuity Trust (GRAT). While the contents of this article were originally prepared in May 2004 when the §7520 hurdle rate that is necessary for the GRAT to be successful was 3.…
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Because of a recent development in the law, an old technique is now more valuable for estate tax reduction planning. This technique is a grantor retained annuity trust (“GRAT”) established in such a manor that the gift has little or no value for…
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In January 2002 the IRS issued a brief Notice outlining new tax rules for the taxation of Split-Dollar Plans. The Notice followed earlier attempts by the IRS to modify the Split-Dollar rules. The rules published in the Notice were a departure from th…
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