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Julius H. Giarmarco

Julius Giarmarco’s Legal Guides

26 total

  • Qualified Personal Residence Trusts (Part 2)

    The QPRT can be designed as a grantor trust. This means that the grantor is treated as the owner of the QPRT for income tax purposes. Therefore, during the term, all property taxes on the residence will be deductible to the grantor. For the same reason, if the grantors primary re...

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  • Qualified Personal Residence Trusts (Part 1)

    A Qualified Personal Residence Trust (QPRT) is an excellent tool for persons with large estates to transfer a principal residence or vacation home at the lowest possible gift tax value. The general rule is that if a person makes a gift of property in which he or she retains some ...

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  • Grantor Retained Annuity Trusts (Part 2)

    Benefits First, if the assets transferred to the GRAT grow (both in accumulated income and appreciation) at a rate higher than the IRSs published interest rate, the value of the assets remaining in the GRAT when the term ends will be greater than the amount that was taxed. This g...

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  • Top 10 Uses of Life Insurance in Non-Taxable Estates (Part 2)

    7. Annuity Arbitrage. Many people, who are adverse to the stock markets daily fluctuations, prefer to park their investments in municipal bonds or certificates of deposit (CDs). In exchange for this security, the yield on these investments is quite low. A better alternative to mu...

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  • Top 10 Uses of Life Insurance in Non-Taxable Estates (Part 1)

    While there is a present lapse in the estate and generation-skipping transfer taxes, its likely that Congress will reinstate both taxes (perhaps even retroactively) some time during 2010. If not, on January1, 2011, the estate tax exemption (which was $3.5 million in 2009) becomes...

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  • Top 10 Uses of Life Insurance in a Family Business Succession Plan (Part 2)

    6. Section 303 Redemptions Internal Revenue Code Section 303 enables the estate of a business owner to remove cash from a corporation with no tax cost. To be eligible for a Section 303 redemption, the stock's value must exceed 35% of the shareholder's estate. Also, the maximum am...

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  • Top 10 Uses of Life Insurance in a Family Business Succession Plan (Part 1)

    A key part of estate planning for business owners who want to keep their business in the family is deciding when and to whom to transfer the business. The particular tools and techniques used in a business succession plan will vary based on the goals and objectives of the four gr...

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  • Installment Sales to Grantor Trusts

    An installment sale to a grantor trust can provide valuable income, gift and estate tax benefits. If the assets sold produce a total return (income and appreciation) in excess of the interest rate on the note, substantial wealth can be removed from the sellers gross estate gift...

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  • Grantor Retained Annuity Trusts (Part 1)

    A Grantor Retained Annuity Trust or GRAT is one of the most powerful and tax efficient wealth transfer tools available today. A GRAT allows a person to transfer the future appreciation of an asset to his/her children with little or no gift tax. The Basics A GRAT is a trust with a...

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  • Three Levels of Business Succession Planning (Part 2)

    LEVEL TWO - OWNERSHIP Often, a major concern for family business owners with children who are active in the business is how to treat all of the children equally in the business succession process. Other concerns for the business owner include when to give up control of the busine...

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