Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / marital-trust-credit-shelter-design-memo.docx
marital-trust-credit-shelter-design-memo.docx
Parties
Harkness LLP
Caldwell Ridgeline Capital LLC
Stonecrest Realty Holdings LLC
Pemberton Valuation Group LLC
Havensbrook Wealth Advisors LLC
Strauss LLP
Meridian Crest Partners LLC
M. Hartfield
Dates
March 28, 2023
October 3, 2010
April 1, 2023
January 15, 2023
April 15, 2023
May 1, 2023
June 1, 2023
July 14, 2023
January 1, 2026
December 31, 2017
Amounts
$2.1
$38,000,000
$134,000,000
$300,000,000
$18,000,000
$60,000,000
$32,195,122
$80,000,000
$29,375,859
$13,953,759
Obligations
The disadvantage is greater administrative complexity, as each trust must track its fractional interest in each asset
QTIP Requirements To qualify for the marital deduction under IRC § 2056(b)(7), the Marital QTIP Trust must satisfy three statutory requirements: 1
Eleanor must be entitled to all income of the Marital QTIP Trust, payable at least annually
The trust instrument must not grant anyone the power to accumulate income or divert income to any person other than Eleanor during her lifetime
The trust instrument must be carefully drafted to ensure that no such power exists
The executor must elect QTIP treatment on the estate tax return (Form 706)