WebJan 1, 2024 · (4) General powers of administration. --A power of administration is exercisable in a nonfiduciary capacity by any person without the approval or consent of … WebI.R.C. § 674 (b) (1) Power To Apply Income To Support Of A Dependent —. A power described in section 677 (b) to the extent that the grantor would not be subject to tax under that section. I.R.C. § 674 (b) (2) Power Affecting Beneficial Enjoyment Only After Occurrence Of Event —. A power, the exercise of which can only affect the ...
Sec. 674. Power To Control Beneficial Enjoyment - irc…
WebThe exact language of Internal Revenue Code Section 675(4) is as follows: “A power of administration is exercisable in a nonfiduciary capacity by any person with - out the approval or consent of any person in a fiduciary capacity”2 and which includes any one or more of the following powers: (A) a power to vote or direct the voting of WebJun 19, 2024 · Renouncing a substitution power created pursuant to Section 675 (4) (C) may appear to change the status of the trust from a grantor trust to a non-grantor trust, … how to remove grey highlight from word
Trust planning opportunities available with swap powers - The Tax …
Web1. Loans to grantor without adequate interest or security under IRC Section 675(2) 2. Power to add charitable beneficiary under Section 674(b)(5) flush 3. Power to reacquire trust corpus by substituting other property of an equivalent value under Section 675(4)(C) ("Swap power") i. Near death swap to take advantage of Section 1014 step-up or ... WebOct 12, 2016 · Similarly, a so-called “substitution power” under IRC Section 675 (4) (C) – which allows the grantor to swap personal assets with trust assets, as long as the substitute asset has equivalent value – also causes the trust’s income to be treated as the grantor’s for income tax purposes, but usually will not cause the assets to be included for … WebI.R.C. § 675 (4) General Powers Of Administration — A power of administration is exercisable in a nonfiduciary capacity by any person without the approval or consent of … no recoil owen gun