21-Year Tax Issues And The Non-Specialist Advisor — Part 4

Part 1 of this Series reviewed what the 21-year deemed disposition rules are and introduced three approaches to planning that appear to be most commonly used to manage the effects of the 21-year deemed disposition rules: Do Nothing, the Simple Roll-Out, and Vesting Indefeasibly. Part 1 of the Series also reviewed the Do Nothing approach. In the second instalment of the Series, the Simple Roll-Out approach was reviewed in detail and the third instalment of the Series reviewed the Vesting Indefeasibly approach.

This fourth instalment¹ will delve into more advanced issues involving planning for trusts nearing their 21st anniversaries that have non-resident beneficiaries.

Distributions of Appreciated Trust Capital Property to Non-Resident Beneficiaries