Every indexed document

and not heirs such as children and grandchildren.

and in general would require that non-spouse beneficiaries withdraw the balance of the

regardless of how the income is characterized at the

but would tax as ordinary income what is viewed as compensation for the

they pass through long-term capital gain to the partners/managers

” or profits from the entity. Because these profits interests are structured as

managers of these entities are often compensated with what are

and may lack the charitable intent necessary for the

given the proposal’s recommended effective date (introduction

and not from a trust. The proposal would

trust distributions on behalf of beneficiaries such

because charity has an ongoing “substantial” income interest in

even though the trust is otherwise subject to GST.

if made inter vivos by an individual [i.e.

the tax law provides that the GST will not apply to “any

insurance trusts that are designed to remove

the proposal provides that if the deemed income tax owner of a

when GST would again apply to the trust.

which are designed to pass potential appreciation at little or no gift-tax “cost

and the basis of property received by lifetime gift would