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The Intersection of Estate Tax Apportionment and Blended ...
that the Family Trust was exempt from federal estate tax apportionment. The majority buttressed its opinion with Rev. Rul. 75-440 and the following rationale: Moreover, were the Family Trust to bear the burden of federal estate taxes, at the time of Mr. Clancy's death, the corpus of that trust would be subject to imposition of federal estate taxes
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