tag:blogger.com,1999:blog-1335076796987605384.post7067925984863988987..comments2024-01-09T07:23:36.400-05:00Comments on Kevin A. Pollock BLAWG: Perfect Time to do Estate Planning for that Vacation HomeKevin A. Pollock, J.D., LL.M.http://www.blogger.com/profile/08329649326376128858noreply@blogger.comBlogger5125tag:blogger.com,1999:blog-1335076796987605384.post-63876903662257941232011-01-04T10:53:58.424-05:002011-01-04T10:53:58.424-05:00Dear PC,
I am not intimately familiar with 877A, ...Dear PC,<br /><br />I am not intimately familiar with 877A, but I would be shocked if it did not apply to QPRTs, regardless of when they were created. The IRS tends to be quite unforgiving when it comes to people expatriating to avoid paying taxes.Kevin A. Pollock, J.D., LL.M.https://www.blogger.com/profile/08329649326376128858noreply@blogger.comtag:blogger.com,1999:blog-1335076796987605384.post-78625942628257748442010-12-29T16:24:23.020-05:002010-12-29T16:24:23.020-05:00Hi Kevin,
Is a QPRT considered part of the grantor...Hi Kevin,<br />Is a QPRT considered part of the grantor's estate and subject to possible unrealized gain if the grantor were to relinquish his U.S. citizenship (IRC Section 877A)?<br />This section of the Internal Revenue Code was passed in 2008 and may not apply to a QPRT established prior.<br />Too bad your clients can't see the tremendous benefits of a QPRT (asset protection and estate planning).Unknownhttps://www.blogger.com/profile/02864562846375225691noreply@blogger.comtag:blogger.com,1999:blog-1335076796987605384.post-25019114046959782682009-06-30T12:38:37.280-04:002009-06-30T12:38:37.280-04:00We too get a lot of clients that feel like they wi...We too get a lot of clients that feel like they will run out of money, even if they are extremely advanced in age. But once we run the numbers and show them the potential estate tax savings of setting up QPRTs, they are usually on board. Thanks again for a great blog post.Diane H. Parriotthttp://www.wbaileysmith.comnoreply@blogger.comtag:blogger.com,1999:blog-1335076796987605384.post-71815543694482682502009-06-30T10:20:58.989-04:002009-06-30T10:20:58.989-04:00Diane,
Most of my clients do not really need/want...Diane,<br /><br />Most of my clients do not really need/want heavy QPRT planning. One of the reasons I wrote the article is because I am having trouble convincing people to gift at all. Even clients in their 80s with over $5,000,000 are worried they are going to run out of money. Moreover, they see less of a need now that the estate tax exemption amount has gone up to $3,500,000. Few stop to think about the hundreds of thousands that can be saved by avoiding the state estate tax.Kevin A. Pollock, J.D., LL.M.https://www.blogger.com/profile/08329649326376128858noreply@blogger.comtag:blogger.com,1999:blog-1335076796987605384.post-47253949297150947752009-06-29T23:21:48.220-04:002009-06-29T23:21:48.220-04:00Great post! We are getting more and more clients ...Great post! We are getting more and more clients interested in QPRTS (I practice in Orange County, CA). Do you ever "hedge your bets" and set up a structure where a single parent puts 2 QPRTs in place, each for a different term, and then in addition to that, gift a small percentage of the residence to a child? For instance, 1% gifted to the child at the time the QPRT is set up, and the remaining 99% divided between 2 different QPRTS with terms of 3 and 5 years? Just curious to hear what your input on that is. Thanks again.Diane H. Parriottnoreply@blogger.com