37. LO.4 In each of the following independent cases, write a memo for the tax research file in preparation for a meeting with Gary. In each memo, explain whether the proposed plan meets his objective of shifting income and avoiding the grantor trust rules.

a. Gary transfers property in trust, income payable to Winnie (his wife) for life, remainder to his grandson. Gary's son is designated as the trustee.

b. Gary transfers income-producing assets and a life insurance policy to a trust, life estate to his children, remainder to his grandchildren. The policy is on Winnie's life, and the trustee (an independent trust company) is instructed to pay the premiums with income from the income-producing assets. The trust is designated as the beneficiary of the policy.

c. Gary transfers property in trust. The trust income is payable to Gary's grandchildren, as Winnie sees fit. Winnie and an independent trust company are designated as trustees.

d. Gary transfers property in trust, income payable to Winnie (Gary's ex-wife), remainder to Gary or his estate upon Winnie's death. The transfer was made in satisfaction of Gary's alimony obligation to Winnie. An independent trust company is designated as the trustee.

FILE MEMO Date Client Name Location Relevant Facts: Specific Issues (add more as needed): 1. 2. Conclusions (each conclusion should address the related specific issue): 1. 2. Support (Citations to Relevant Authority): Issue One [Include Support for Specific Issue 1 here] Issue Two [Include Support for Specific Issue 2 here] Actions to Be Taken: ____ Discuss with client Date discussed ____ Prepare a memo or letter to client ____ Explore other fact situations ____ ____ Other action Preparer: __________________________ Date: __________ Reviewer: __________________________ Date: __________