Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / state-income-tax-planning-memorandum.docx
state-income-tax-planning-memorandum.docx
Parties
Harkness LLP
State Inc
Strathmore Corp
Greaves LLP
Havensbrook Wealth Advisors LLC
Stonecrest Realty Holdings LLC
Ridgeline Capital Fund IV LP
Whitmore Partners LLC
Dates
May 10, 2023
April 1, 2023
April 15, 2023
May 1, 2023
June 1, 2023
April 15, 2025
May 1, 2026
June 1, 2026
March 15, 2023
January 1, 2024
Amounts
$300,000,000
$112,000,000
$134,000,000
$38,000,000
$12,000,000
$14,000,000
$9,000,000
$7,000,000
$5,000,000
$100,000
Obligations
New York Source Income Test (Prong 2) and New York Real Property Test (Prong 3) Even if the trustee domicile issue is resolved, the Dynasty Trust must also satisfy the second and third prongs of the exempt resident trust test — namely, it must not hold assets that generate New York source income, and its corpus must not include real or tangible personal property located in New York
Of course, any such distribution decisions must be made in accordance with the HEMS standard and the Distribution Committee approval requirements set forth in the trust instrument, and must be guided by the legitimate needs of the beneficiaries rather than solely by tax considerations
Dynasty Trust Filing Obligations The Caldwell Family Dynasty Trust has the following filing obligations: Federal Filing The Dynasty Trust must file Form 1041 (U
Delaware Filing The Dynasty Trust is required to pay the annual $200 Delaware filing fee applicable to trusts with a Delaware trustee
Connecticut and Illinois Filing The Dynasty Trust does not have a filing obligation in Connecticut or Illinois unless it is required to file in those states as a nonresident trust with source income in those states
The allocation of GST exemption to the GRAT remainder interests must await the expiration of the ETIP for each GRAT, as discussed in Section V