Question
In 2013, Moira creates a trust to benefit her daughter Nancy and her twin grandchildren Oliver and Penelope. The terms of the trust provide that
In 2013, Moira creates a trust to benefit her daughter Nancy and her twin grandchildren Oliver and Penelope.The terms of the trust provide that all income is to be accumulated until Oliver and Penelope reach age 25, at which time the trust will terminate and the corpus will be paid to Oliver and Penelope in such shares as Nancy directs.The trust provides that Nancy may execute a document directing what happens to the corpus at any time while Nancy is alive, or do so in her will.Nancy is also given the noncumulative power to withdraw $75,000 from the trust each November for any reason she wants.La Jolla National Bank is named trustee.
Nancy dies on November 1, 2016.Moira, Oliver, and Penelope are still alive (Oliver and Penelope are 22). Nancy's will states that the corpus is to be distributed equally among Oliver and Penelope when they reach 25.Nancy had never exercised her power to withdraw money from the trust, which had the following values during the relevant times:
2013: $500,000
2014: $1,000,000
2015: $1,000,000
2016: $1,500,000 (The income interest was worth $200,000 and the remainder interest was worth $1,300,000).
Question:
- What is included in Nancy's gross estate due to the foregoing events?Please explain.Do not discuss any gift tax consequences from the foregoing and do not calculate any actual gift or estate tax liability.
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