Question
Which one of the following transfers made this year by 85-year old Jennifer is not sooner or later subject to the Generation Skipping Transfer Tax?
Which one of the following transfers made this year by 85-year old Jennifer is not sooner or later subject to the Generation Skipping Transfer Tax?
a. A gift of a remainder interest in a trust just established which is paying an income interest to Jennifer. The remainderman is a grandson whose parents died in an auto accident earlier this year before the inception of the trust.
b. A transfer by Jennifer of $15,000 to a UTMA account established by her son for Jennifer's granddaughter.
c. An irrevocable trust which pays income to Jennifer for 10 years and then pays the remainder to her grandniece who is only 25 years younger than Jennifer.
d. An irrevocable trust which pays income to Jennifer's daughter for life, then distributes the remainder to the grandchild of a friend and that grandchild is currently 31 years old.
Which of the following is not necessary to properly execute a Section 303 stock redemption?
a. | The value of the stock must be greater than 35% of the decedent's adjusted gross estate, including gifts made in the last 3 years. | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
b. | The 303 redemption can only be used if the corporation has the cash to redeem the shares. | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
c. | The 303 redemption can be made without a positive earnings and profits account. | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
d. | The Section 303 redemption is limited to an amount that cannot exceed the death taxes of the estate, plus funeral and administrative expenses for which the decedent is liable.
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The Generation Skipping Transfer Tax (GSTT) has all the following characteristics, except:
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