Income Taxation of Fiduciaries and Beneficiaries (2014)

Book excerpt: Income Taxation of Fiduciaries and Beneficiaries provides stepbystep guidance on the taxation of fiduciary income. This comprehensive guide for practitioners advising fiduciaries and beneficiaries in federal income tax matters covers the broad range of complex issues from charitable remainder trusts to nexus rules and their effect. Providing expert practical advice, Income Taxation of Fiduciaries and Beneficiaries helps the practitioner obtain the most advantageous outcomes for his/her fiduciary and beneficiary clients. Key feature: 35 case studies with filledin forms 1041 and accompanying documents. Highlights include: * IRA divided into subtrusts beneficiaries, not trusts, are taxable * Grantor trusts * IRS reaffirms position on Rev. Rul. 8513: deemed owner reflects all tax items of income, deduction, credits, etc. * More on toggling to/from grantor status * Member of distribution committee is not treated as a grantor * How to factor/value reversionary interest * Late filing election for QSSTs is simplified: need for PLR deleted * Reformation of CRUT to reflect change in regulations that had retroactive effect * Regulations issued on PFIC reporting and QEF treatment * State decanting provisions * Adding beneficiary to wholly discretionary trust is a nontaxable event * Material Participation tests: * IRS expands criteria * Passive activity and net investment income considerations * Docketed tax court case on real estate activities status * New tax rates on trust and estates * Substantial detail on deductions and distributions for NII /surtax calculations * Related back applies to Subchapter J, tier 1/1/2 calculations, not relevant for FAI * When passive activity realizes income, NOL carryover is freed up