Trusts, Estates & Probate

FastTrack

4.5

Modifying Trusts: Tax Reimbursement Clauses After the New IRS CCA

Credits Available
Credit Status Total
Alaska CLE Approved 1 Total
Arizona CLE Approved 1 Total
California CLE Approved 1 Total
Colorado CLE Approved 1 Total
Connecticut CLE Approved 1 Total
Delaware CLE Approved 1 Total
Hawaii CLE Approved 1 Total
Iowa CLE Upon Request 1 Total
Idaho CLE Approved 1 Total
Illinois CLE Approved 1 Total
Louisiana CLE Upon Request 1 Total
Maine CLE Approved 1 Total
Minnesota CLE Approved 1 Total
Missouri CLE Approved 1.2 Total
Northern Mariana Islands CLE Approved 1 Total
Montana CLE Approved 1 Total
North Dakota CLE Upon Request 1 Total
Nebraska CLE Approved 1 Total
New Hampshire CLE Approved 1 Total
New Mexico CLE Approved 1 Total
Nevada CLE Approved 1 Total
New York CLE Approved 1 Total
Oklahoma CLE Approved 1 Total
Oregon CLE Approved 1 Total
Pennsylvania CLE Approved 1 Total
Rhode Island CLE Upon Request 1 Total
Vermont CLE Approved 1 Total
Washington CLE Approved 1 Total
Wisconsin CLE Approved 1 Total
West Virginia CLE Approved 1.2 Total
Wyoming CLE Upon Request 1 Total
OnDemand
59 minutes
Kenneth Hunt
With Kenneth F. Hunt from Hodgson Russ LLP
Recorded March 29, 2024
Product ID 98876

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Overview

Understand What the Decision Means to Planning With Trusts

The recent IRS ruling on an irrevocable trust modification to reimburse grantor for income tax expenses was a surprising pivot in the way the IRS has treated trust modifications in the past. Now practitioners are trying to make sense of the facts of the specific case and to decipher the future implications of the CCA. In this legal course our experienced tax faculty will analyze the decision and outline the changes attorneys and fiduciaries will need to make to their daily practices. Register today!

  • Determine what types of trusts and actions are affected.
  • Adapt your current drafting and planning tactics to comply with the new restrictions.
  • Gauge the broader potential implications of the decision for the trusts and tax practice.
  • Explore potential planning alternatives.

Abbreviated Agenda

  1. Adding Tax Reimbursement Clauses to Trusts: Previous Case Law and IRS Guidance
  2. November 2023 Chief Counsel Advice (CCA): Facts, Issues, Analysis, and Conclusions
  3. Future Implications of the CCA to Trust Drafting and Modifications
  4. Tax Planning and Reporting Takeaways
  5. Broader Outlook: IRS Views on Making Changes to Irrevocable Trusts
  6. Potential Planning Alternatives and Workaround Ideas

Related Topics

Product ID 98876

Credit Details

Credits Available
Credit Status Total
Alaska CLE Approved 1 Total
Arizona CLE Approved 1 Total
California CLE Approved 1 Total
Colorado CLE Approved 1 Total
Connecticut CLE Approved 1 Total
Delaware CLE Approved 1 Total
Hawaii CLE Approved 1 Total
Iowa CLE Upon Request 1 Total
Idaho CLE Approved 1 Total
Illinois CLE Approved 1 Total
Louisiana CLE Upon Request 1 Total
Maine CLE Approved 1 Total
Minnesota CLE Approved 1 Total
Missouri CLE Approved 1.2 Total
Northern Mariana Islands CLE Approved 1 Total
Montana CLE Approved 1 Total
North Dakota CLE Upon Request 1 Total
Nebraska CLE Approved 1 Total
New Hampshire CLE Approved 1 Total
New Mexico CLE Approved 1 Total
Nevada CLE Approved 1 Total
New York CLE Approved 1 Total
Oklahoma CLE Approved 1 Total
Oregon CLE Approved 1 Total
Pennsylvania CLE Approved 1 Total
Rhode Island CLE Upon Request 1 Total
Vermont CLE Approved 1 Total
Washington CLE Approved 1 Total
Wisconsin CLE Approved 1 Total
West Virginia CLE Approved 1.2 Total
Wyoming CLE Upon Request 1 Total
Select Jurisdiction
CLE

Agenda

All times are shown in

  1. Modifying Trusts: Tax Reimbursement Clauses After the New IRS CCA

    1. Adding Tax Reimbursement Clauses to Trusts: Previous Case Law and IRS Guidance
    2. November 2023 Chief Counsel Advice (CCA): Facts, Issues, Analysis, and Conclusions
    3. Future Implications of the CCA to Trust Drafting and Modifications
    4. Tax Planning and Reporting Takeaways
    5. Broader Outlook: IRS Views on Making Changes to Irrevocable Trusts
    6. Potential Planning Alternatives and Workaround Ideas

Who Should Attend

This legal briefing is designed for attorneys. Accountants, tax professionals, fiduciaries, and paralegals will also benefit.

Speakers

Kenneth F Hunt
Kenneth F.
Hunt
Hodgson Russ LLP
Speaker bio
Kenneth F Hunt

Kenneth F. Hunt

Hodgson Russ LLP
Kenneth Hunt

is a partner with Hodgson Russ LLP. He regularly advises individuals, families, beneficiaries, corporate and individual fiduciaries regarding all aspects of complex estate and trust planning, administration, and litigation; and related federal, state, and local estate, gift, and income tax issues. Mr. Hunt's experience includes several audits of gift and estate tax returns and the preparation of and filing of complex federal and state gift, estate, and fiduciary income tax returns, including estate tax returns for nonresident decedents. He also advises business owners on business succession planning and various asset protection planning strategies, including the use of domestic asset protection trusts. Mr. Hunt is admitted to practice in Delaware, Massachusetts and New York. He earned his B.A. degree, magna cum laude, from Providence College; his J.D. degree, magna cum laude, from Syracuse University School of Law; and his LL.M. degree, in taxation, from New York University School of Law.

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