In his Estate Planning and Philanthropy column, Conrad Teitell, a partner at Cummings & Lockwood, delves into the legal meaning of "allowable" and asks: Does "allowable" transmogrify to "not allowable" because under particular circumstances the estate tax deduction isn't claimed even though under different circumstances it would be claimed, thus making it "allowable"?
April 25, 2011 at 12:00 AM
1 minute read
Does the law of unintended consequences strike again? A donor died in 2010 with a large estate. Among his bequests is a testamentary charitable remainder unitrust. If his estate elects modified carryover basis (instead of the retroactive estate tax regime for 2010), has a qualified CRUT been created?
Treasury Reg. §1.664-1(a)(1)(iii)(a) defines a unitrust and an annuity trust (CRT) as a trust for which a tax deduction is allowable for income, gift or estate tax purposes.
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