Around the Water Cooler this morning, we look at decanting (of trusts, not wine), a fascinating story of business succession done well from Canada, the 100th anniversary of the estate tax and September interest rates.
- In “Decanting Emerges As a Powerful Tool,” Sabino Biondi details an often underused technique to deal with unanticipated circumstances in administering trusts.
- The Wall Street Journal takes a detailed look at business succession done right in “Canada’s Desmarais Clan: A New Generation Takes Control.”
- Over at the TaxProf Blog, Paul Caron marks the 100th anniversary of the estate tax.
Finally . . . September interest rates. The current § 7520 rate for use with estate planning techniques such as GRAT’s, CRT’s, CLT’s, and QPRT’s is 1.4%. The applicable federal rate (“AFR”) for use with an intra-family loan having a duration of 3 – 9 years, a sale to a defective grantor trust, or a self-canceling installment note (“SCIN”) is 1.22%.
The low § 7520 and applicable federal rates continue to present planning opportunities with GRAT’s, sales to defective grantor trusts, SCIN’s and intra-family loans with depressed assets that are expected to perform better in future years.