“Based upon the detailed discussion that follows, we have concluded that there is a solid argument that there is a basis adjustment to the fair market value of the assets of a grantor trust on ...

the IRS added the following item to its list of matters on which it would not issue letter rulings:[v] “Section 1014. Basis of Property Acquired from a Decedent. Whether the assets in a grantor ...

If the assets of an irrevocable grantor trust are not included in grantor’s gross estate upon his or her death, those assets do not get a Sec. 1014 basis step-up, the IRS clarified Wednesday in Rev.

procedure or regulation), it wouldn’t issue private letter rulings or determinations on whether assets in a grantor trust receive an Internal Revenue Code Section 1014 basis adjustment at the ...

Revenue Ruling 2023-2 is brief. Per the Internal Revenue Service, completed gifts to an irrevocable grantor trust will not receive a basis step-up upon the death of the grantor. Mechanically ...

This power to substitute assets offers the grantor the opportunity to preserve potential losses from depreciated assets, which would otherwise disappear at death. Under section 1014, the tax basis of ...

The basis of appreciated assets held in an IDGT is not stepped-up upon the death of the grantor, notwithstanding the fact that the grantor is treated as the owner of those assets for income tax ...

They had been hoping that by paying income taxes on the income of a completed-gift trust under the grantor trust powers, the trust would be eligible for both a step-up in basis and for estate tax ...

However, trust grantor powers can impact whether a trust or estate is subject to both income taxes and estate or transfer taxes. Qualifying for a step-up in basis of trust assets Many grantor ...

Most notably, assets held in an irrevocable grantor trust may not enjoy a step-up in basis for generations. One of the first steps you will likely undertake in an estate plan is gifting assets so ...

A grantor retained annuity trust (GRAT ... their availability and usefulness must be evaluated on a case-by-case basis, with a view to the circumstances, and especially the arithmetic, in each ...