[WSBAPT] 2519 and termination of QTIP

[Nathan Hayes]

Tom,
Looking forward to meeting you - how about lunch sometime this week or
next?  I am resurrecting my law career after retiring in 2000 and am
looking to meet estate planning folks here in Olympia.  I really don't know
anyone yet.
Nathan

On Sun, Nov 30, 2014 at 2:25 PM, Thomas E. Gates <tegatesesq at gmail.com>
wrote:

> What an outstanding offering!
>
> Tom
>
> Sent from my iPad
>
> On Nov 30, 2014, at 1:56 PM, Nathan Hayes <hayesn03 at gmail.com> wrote:
>
> Katherine,
>
> I have been out of town and just catching up on emails.  I am a relative
> newcomer to Washington, but practiced estate and business succession
> planning in New York for over 12 years.
>
> Here’s my understanding of the facts:  a deceased spouse’s estate is
> valued at $15M and his Will leaves everything to his surviving spouse in a
> QTIP eligible trust; the surviving spouse also has assets valued at $15M,
> she owns those assets outright, and her agent is making lifetime gifts of
> those assets to family members under a power of attorney.
>
> In my estimation the best outcome, tax-wise, is to revoke any QTIP
> election made if you are still within the time to do so, or simply not make
> the election, and bring a TEDRA action to reform the husband’s Will to
> allow the surviving spouse to take the assets in her husband’s testamentary
> trust (above his applicable exclusion amount)* outright*.  That way you
> are assured to have the transfer to her qualify for the estate tax marital
> deduction. Once she owns the assets outright, have her agent give those
> assets away to family members under the power of attorney.  The gifts to
> family members could be outright, in trust or through entities.  (For
> details, see below).
>
> It is not clear to me whether a QTIP election has been made by the
> husband’s executor with respect to the property in the husband’s
> testamentary trust. If made, and the trust otherwise qualifies for QTIP
> treatment, then the property in the trust qualifies for the estate tax
> marital deduction in his estate and is includible in the surviving spouse’s
> estate under section 2044.  If the executor did not make a QTIP election,
> and the trust doesn’t otherwise qualify for the estate tax marital
> deduction under some other section of the Code, then there is no marital
> deduction for his estate to claim and the value of the trust property
> ($15M) is includible and taxed in the husband's estate, with no off-setting
> deduction.
>
> An executor generally has at least 15 months (nine-month due date for
> filing decedent’s Form 706 plus a six-month extension) after the decedent’s
> death to make the QTIP election.  Once made, the election is irrevocable,
> although an election can be modified/revoked on a subsequent return filed
> on or before the due date of the 706 return (including any extensions of
> time actually granted).  It is also not clear to me, if an election was
> made, whether there is still time to modify/revoke it.
>
> *If no QTIP election has been made:*
>
> *Maintain Status Quo (not recommended)*:
> - He died with $15M in his estate.  If no QTIP election was made, (and his
> testamentary trust does not otherwise qualify for the estate tax marital
> deduction), then no marital deduction is available in his estate, and the
> full $15M subject to taxation in his estate.
> - His executor could use his applicable exclusion amount (AEA) in his
> estate ($5.43M in 2014).
> - If he died in 2014, the combined (fed & state ) estate tax due on his
> $15M estate (after applying the AEA) would be:  *$6,554,000* (estimated)
> - ouch!
> - After his death, she could transfer her interest in the testamentary
> trust to younger family members all she wants, but unless the transfer from
> his estate to her qualifies for the estate tax marital deduction, his
> estate will be taxed on the whole $15M, and her subsequent gifts of it or
> from it will not change that fact.
>
> *Testamentary Transfers Between Spouses the Qualify for the Unlimited
> Marital Deduction*:
>
> There are two main ways a testamentary transfer from one spouse to the
> other qualifies for the estate tax marital deduction: (1) outright
> transfers (which will always qualify, so long as the surviving spouse is a
> U.S. citizen) and (2) transfers into any one of four types of trusts,
> reserving a lifetime interest for the surviving spouse: (a) a QTIP trust,
> (b) a General Power of Appointment (GPOA) Trust, (c) a Charitable Remainder
> Trust (CRT), or (d) an Estate Trust.
>
> If his no election was made on his testamentary QTIP eligible trust, and
> the trust doesn’t otherwise qualify (in other words it doesn’t meet the
> requirements for a GPOA Trust, a CRT or an Estate Trust) then perhaps the
> best way to qualify the testamentary transfer from him to her is to reform
> his Will and have the assets in the trust pass directly to her, free and
> clear.
>
>
> *Options* (still assuming no QTIP election):
>
> 1) Bring a TEDRA action to reform the Will to have her take everything
> outright except his AEA ($5.34M if he died in 2014).
> - Is there language in the Will as to an alternate disposition?
> - I am assuming family members will consent.
> - Outright to her qualifies for the marital deduction, shifting the
> property to her estate.
> - No federal estate tax due in his estate (his AEA is applied to zero-out
> his estate tax).
> - WA state estate tax due on his $5.34M estate (after applying WA estate
> tax credit and assuming he died in 2014):  $791,200 (estimated).
> - Although it would be relatively small in amount, a PTP (previously taxed
> property) credit would be available to her estate for Washington State
> estate taxes paid in his estate (based on the actuarial value of her life
> income interest on the $5.34M that was held back in his estate) *IRC
> section 2013.*
> - From the roughly $10M she gets outright from his estate via the TEDRA
> order: (1) make nontaxable annual exclusion gifts of $14,000 per donee in
> Dec 2014  and again in Jan 2015, (2) make taxable gifts of up to $5.34M
> (her AEA in 2014) in Dec 2014 and pay no tax - to minimize the risk of
> mortality, (3) make a taxable gift of $90,000 in Jan 2015 - the difference
> between her 2015 AEA ($5.43M) and her 2014 AEA ($5.34M) - and pay no gift
> tax, and (4) make taxable gifts above her 2015 AEA ($5.43M) in Jan 2015 and
> pay gift tax.  I would report *all* gifts (even annual exclusion gifts)
> on timely filed Form 709s.
> - On Form 709, allocate appropriate GST tax exemption amounts to any
> direct skip gifts to grandchildren or other skip persons so as to create a
> zero inclusion ratio.
> - Your email didn’t indicate so, but I am assuming the POA is durable,
> which would be critical, given her mental condition.
> - As a general principle, because of the tax-inclusive nature of the gift
> tax (meaning the tax is calculated on the gift only and not the total
> property removed from the estate), and the fact that the state of
> Washington does not have a gift tax, gift taxes are cheaper than estate
> taxes.
> - If she dies within 3 years of making outright gifts, the amount of gift
> taxes paid will be brought back into her estate, but *not* the gifted
> property itself.  *IRC section 2035(b)** .*
> - The value of the taxable gifts she makes will, however, be used to
> calculate the estate tax on her estate (using date of gift values rather
> than date of death values). As a result, it would be advantageous to have
> her make taxable gifts of assets likely to appreciate in the near-term.  If
> you have a choice, use the unproductive or fixed-income assets for annual
> exclusion gifts, and use assets that are likely to increase in value over
> the next year or two for the taxable gifts.
> - If her attorney-in-fact has the authority to create a FLP or LLC for her
> and there is a legitimate business reason for doing so, consider having her
> attorney-in-fact create a FLP or LLC and transfer property into the
> entity.  Merely transferring assets into the entity will reduce their value
> for transfer tax purposes (because ownership interests in the FLP or LLC
> would be harder to sell than the underlying assets).  The attorney-in-fact
> could then make gifts of minority ownership interests in the entity at
> discounted values (potentially discounted by 20%-40%).  There have been
> cases where near-death transfers of assets into FLPs or LLCs have been
> upheld (others not), but I would have to know more about the assets, the
> intentions of the parents, the overall family situation, and the business
> justification for creating the entity to comment more.  The fact that she
> is incompetent and near the end of her life makes the FLP/LLC option more
> challenging to justify.  It may be worth discussing with your client(s), if
> you haven’t already. The set-up costs, annual accountings and tax returns
> for the entity, risk of her death in mid-stream before the arrangement is
> finalized, and the risk of an IRS attack, predominatly under section 2703,
> must be taken into consideration.  With the dollars involved here, the
> transfer tax savings could be significant.
> - Using a GRAT with a one to two year term might be a possibility
> (assuming the attorney-in-fact has authority under the POA to create
> trusts).  The AFRs are still quite low (2%-2.5% last time I looked) and all
> the trustee of the GRAT would have to do is outperform the APRs to create a
> transfer tax savings, although the potential tax savings might not be worth
> the legal, accounting, and fiduciary fees and commissions involved with the
> trust.  You’d have to run the numbers.  Of course there is the mortality
> risk as well - if she dies before the end of the term, the remaining
> portion of her annuity interest would be includible in her estate.
>
> 2) Have her disclaim everything other than his AEA.
> - On the federal level, a *qualified *disclaimer is a nontaxable event.  *IRC
> section 2518.*
> *- *Is a disclaimer not an option here because 9 months has elapsed since
> his date of death or because she has accepted some of the benefits under
> his testamentary trust? (Either one would disqualify the disclaimed
> property from transfer tax exclusion).
> - If she was able to make a qualified disclaimer, is there any language in
> his Will as to an alternate disposition?
> - If she makes a qualified disclaimer and the property disclaimed goes
> under the laws of descent and distribution (intestate), she would get most
> of the disclaimed property back anyway.
>
> *If a (full) QTIP election has been made:*
>
> - If the QTIP election has already been made for his testamentary trust,
> and the trust meets the requirements for a qualified terminable interest
> under section 2056 (b)(7), a marital deduction for the QTIP trust is
> available in his estate, reducing its value to zero; therefore no estate
> taxes due on his estate.
> - The $15M QTIP trust property is placed in her estate by statute. *IRC
> section 2044.*
> *- *“Port” his DSUE (deceased spouse’s unused exclusion) amount by making
> the portability election on a timely filed Form 706.
> - The DSUE amount may be used by her any time after his date of death,
> provided that portability has been or will be properly elected.  *Temp.
> Reg section 25.2505-2T(a) *(Note: check to see if that temporary
> regulation has been finalized, and if so, check to see if there were any
> changes made).
> - Make nontaxable annual exclusion gifts of $14,000 per donee in Dec 2014
> and again in Jan 2015;  make taxable gifts up to her BEA (basic exclusion
> amount) plus his DSUE amount in 2014 without paying tax; and make taxable
> gifts over her BEA + his DSUE in 2015 and pay gift tax. (Note: BEA and AEA
> are the same; the code simply changed the name to BEA in reference to the
> surviving spouse)
> - File Form 709 for each year, and make a reverse QTIP election for GST
> tax purposes if gifts are made to grandchildren or other skip persons and
> allocate appropriate GST tax exemption amounts.
>
> If the QTIP election has been made, it may be tempting to have her give
> the trust assets away as I have outlined immediately above.  However,
> here’s where it gets sticky:
>
> Under section 2519, the transfer of an income interest in a QTIP trust is
> treated as a transfer of the entire interest (income and principal), which
> would cause the QTIP to lose its status as a qualifying terminable interest
> for the marital deduction.  As a result, the disqualified QTIP trust
> property would be brought back into *his* estate and be subjected to
> estate taxation. If you have already ported his DSUE, then his estate would
> have to pay estate tax on $15M with no AEA to use.
>
> The four basic requirements to qualify a QTIP trust for the marital
> deduction are:  (1) the surviving spouse must have the right to all income
> for life, (2)  the surviving spouse must be the sole lifetime beneficiary,
> (3) during the life of the surviving spouse, there can be no right to
> divert trust property to anyone else (other than the surviving spouse), and
> (4) the deceased spouse’s executor must make a timely election to treat the
> trust property as QTIP. *IRS section 2056(b)(7).*
>
> Consider the possible ways she could transfer out her interest in the QTIP
> trust property:
>
> 1) She could transfer or assign her rights in the trust to family members,
> but that would disqualify the QTIP for the marital deduction and bring the
> trust property into his estate under section 2519.
>
> 2) I am not convinced that a TEDRA action would bring any different
> result. Any transfer by her to someone else (whether voluntarily made by
> her or pursuant to court order) is going to disqualify the marital
> deduction for the QTIP trust and thereby make his previously nontaxable
> estate subject to estate tax on whatever is in the trust.  A state court
> judge’s order is not going to trump a federal statute.
>
> 3) She could disclaim, although, again, I am not sure whether she could
> make a qualified (i.e., tax-free) disclaimer at this point, and I do not
> know what the disposition would be if she were to disclaim.
>
> As a result, if the QTIP election has been made and cannot now be
> modified, I don’t see any advantage of going through the expense and
> uncertainty of a TEDRA action, nor do I see any advantage in her making a
> gift of her interest in the QTIP trust. The impact of a qualified
> disclaimer, if it is even available, depends on what the alternate
> disposition would be.
>
> On the other hand, if the QTIP has not been made or can still be revoked,
> then a TEDRA action reforming the trust so as to allow her to take outright
> the amount over his AEA and then gifting that amount to others, consistent
> with her husband’s overall estate plan, makes the most sense to me.  As an
> alternative, you could reform the trust so as to have the entire trust
> property distributed to her outright and then simply port his DSUE and
> apply it to the gifts out - the net effect would be the same as the way I
> have proposed.  My thinking on that would be the less you attempt to change
> in the TEDRA action, the better.
>
> If there is still time to make or modify the QTIP election, it is
> conceivable that a partial election could be made, but I don’t see how that
> would resolve the overall transfer tax issue any better than simply not
> electing QTIP treatment or revoking a previous election.
>
> The best outcome, transfer tax-wise, is to not elect to treat the trust as
> a QTIP trust and bring a TEDRA reformation action to get the trust assets
> (over his AEA) to her outright and then have her attorney-in-fact give
> those assets away.  A transfer into a FLP or LLC (assuming a legitimate
> business purpose) or a GRAT, if the attorney-in-fact has the authority to
> do so, would allow you to “leverage” the gifts, creating a greater transfer
> tax savings than outright gifts, although there are risks involved in their
> use.
>
> If the QTIP election was made and the due date on the husband’s Form 706
> (with any extensions granted) has passed, you may want to dig into the regs
> to see under what circumstances, if any, the IRS has discretionary
> authority to accept a late revocation.
>
> If you are absolutely stuck with a QTIP election, then perhaps it’s simply
> a matter of determining which way would your client(s) like to take the
> estate tax bullet - through her estate (via section 2044 without any
> subsequent gifting) or his (via section 2044 and then making transfers that
> disqualify the marital deduction in his estate).…its gonna hurt either way.
>
>
> *As to the $15M of assets in her name:*
>
> - Have her agent give her assets away (except what will be needed to
> support her for the rest of her life), either by direct gifts or by way of
> a FLP, LLC or GRAT, and pay the gift tax on any taxable gifts if no AEA or
> DSUE is available.
> - Ideally the gifts would be made to the same individuals or class(es) of
> beneficiaries as named in her Will or other estate planning documents, if
> any, made while she was competent.  If any minors are involved, transfers
> of up to $14,000 to an UTMA/UGMA account or a section 2503 minor’s trust
> would qualify as annual exclusion gifts, even though the minor wouldn’t
> have the right to demand access to the funds until reaching age 21.  Gifts
> over $14,000 to a custodian of a UTMA/UGMA account or a trustee of a
> minor’s trust would be fine too, although taxable.
> - As is the case with the assets originating from his testamentary trust,
> if she dies within 3 years of making gifts of her assets, any gift tax paid
> will be included in her estate but not the gifted property itself - unless
> a FLP or LLC is used and the IRS is successful in arguing that the assets
> should be brought back into her estate under section 2036 or 2038 (too much
> retained control).
>
>
> *Charitable gifts:*
>
> I don’t know if your client(s) have any philanthropic intentions, and I
> don’t know the ages or financial situations of the younger family members,
> but have you considered something like a 10 year Charitable Lead Annuity
> Trust (CLAT)?  Again, with AFRs so low, if the trust outperforms them, you
> will have leveraged the gifts to the family members, while obtaining a
> substantial charitable deduction for mom’s estate. If mom, while she was
> competent, either through her estate planning documents or her actions,
> demonstrated an inclination to benefit charitable organizations, and her
> attorney-in-fact has express authority to create trusts on her behalf and
> make gifts to anyone, then a CLAT might be a viable option to consider.
> The younger family members would just have to wait 10 years to receive the
> assets in the CLAT.
>
> Thanks for sharing this case with the listserv.  I hope this response is
> helpful to you.  Please accept it cafeteria-style:  take what you’d like
> and leave the rest.
>
> If something I have written here is not clear or your
> understanding/viewpoint is something different from what I have expressed
> and you would like to discuss things further, please feel free to call me
> or email me back either directly or via the listserv.
>
> Sincerely,
>
> Nathan M. Hayes
> P.O. Box 2204
> Olympia, WA 98507
> (360) 481-8966
> hayesn03 at gmail.com
>
>
>
>
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>
> On Nov 21, 2014, at 11:41 AM, Katharine P. Bauer <kpb at BPBLEGAL.COM> wrote:
>
> Thanks, Sam.  That is about what I was thinking.  Joint estate of $30m
> sorry I wasn't clear.  We were wondering about terminating the QTIP and
> passing the income interest to her and balance to kids, not through
> disclaimer (would incur fed and state estate taxes) but by TEDRA.
> Interesting situation where the family wants to avoid Washington State tax
> to the greatest extent, since there is no gift tax here (yet). She is
> definitely disposing of her half of the estate (yes $15 million).  If
> *she* has both their exemptions and uses them individually, he is not
> incurring Washington estate tax by transferring to her and she is taxed
> upon the gift at termination for federal purposes.  Just trying to figure
> out how to get it all to her and she makes all the taxable gifts during her
> lifetime.....Now, the coffee has worn off and I need more! :)
> Have a good weekend.
>
> On Fri, Nov 21, 2014 at 11:10 AM, Sam Furgason <sam at furgasons.com> wrote:
>
>> Katherine,
>>
>>
>>
>> If you have sufficient funds to merit a federal QTIP, his estate should
>> have no DSUE because you will have used all of his exclusion amount. That
>> should apply unless the first spouse was impecunious, in which case DSUE
>> would apply (but your post refers to her “half”). ($30m/2 = $15m, which is
>> >$5,340k.) The same logic would apply if the first decedent’s estate is
>> $30m (your question does not make it clear in my mind whether the first
>> spouse’s estate is $30m or the entire community estate is $30m, but implies
>> the latter.)
>>
>> As for terminating the QTIP (which I believe gifting of any income
>> interest would do, per 2519), see if the QTIP language permits liberal
>> distributions to the surviving spouse. If so, you could make large
>> distributions to the spouse and she could make gifts, without terminating
>> the entire QTIP. Since we are near a year end, she could make multiple
>> annual exclusion gifts and reduce her taxable estate somewhat. Those gifts
>> would be tax free, and could be spread among children, grandchildren, and
>> spouses.
>>
>> Also, if she gives away her own estate entirely, then withdrawals from
>> the QTIP are more reasonable, if there is some sort of HEMS type
>> restriction in place.
>>
>> Is a QTIP “termination” even necessary?
>>
>> Don’t forget, the executor makes the QTIP election; it’s not automatic.
>> His executor can make a partial QTIP election rather than a full one, or no
>> election at all, so that the portion of the decedent’s trust which is QTIP
>> eligible can be defined as part of the overall plan. You can time this
>> also, since the federal and state exclusion/exemption amounts rise on
>> 1/1/2015. I don’t think the annual exclusion is changing for next year, but
>> if you have 5 eligible gift recipients, that’s an extra $70k which will not
>> be taxed at either the state or federal levels, thereby justifying  a part
>> of your fees.
>>
>>
>>
>> S
>>
>>
>>
>> *From:* wsbapt-bounces at lists.wsbarppt.com [mailto:
>> wsbapt-bounces at lists.wsbarppt.com] *On Behalf Of *Katharine P. Bauer
>> *Sent:* Friday, November 21, 2014 8:22 AM
>> *To:* probate
>> *Subject:* [WSBAPT] 2519 and termination of QTIP
>>
>>
>>
>> Query:
>>
>> I have a large probate ($30 million) where the first spouse died and his
>> Will funds a QTIP for his surviving spouse.  We are contemplating using
>> portability to transfer his unused amount to his spouse. Surviving spouse
>> is incompetent and unlikely to live a long time.  Her POA has extremely
>> broad powers - of gifting, disclaiming and ability to transfer to other
>> trusts and family. Her AIF is in the process of gifting away her half of
>> the estate, utilizing her fed applicable exemption amounts (no Washington
>> gift tax) and paying any gift tax incurred.
>>
>>
>>
>> First, We are curious as to when she may use her spouse's amount in
>> gifting.  Is it after the IRS accepts his 706?  She likely won't live that
>> long.
>>
>>
>>
>> Second, we are curious about terminating the QTIP and either giving her
>> the life income interest or all of the trust.  The thought is to again gift
>> it to children if she takes it all.  Does 2019 cause any further damage by
>> pulling it into her "estate" and incurring gift tax?  She will have used
>> all of her fed exemption anyway and will definitely incur further incur
>> gift tax.  The purpose here would be to avoid the Washington state estate
>> tax on the extra $15 million  by disposing of it now.
>>
>>
>>
>> Finally, and third, by paying gift tax now, does 2035 pull it back into
>> her estate if she dies prior to 3 years, which she will?  I am having
>> trouble interpreting the statute when we are contemplating terminating the
>> QTIP and gifting her the income interest or all of it....
>>
>>
>>
>> We could simply disclaim QTIP assets under husband's estate but then it
>> would incur the Washington tax.
>>
>>
>>
>> I have reviewed 2511, 2519 and 2035.  Since this is a 3:00 a.m. thought,
>> I would appreciate any and all comments as to whether this is a good idea.
>> After I have my coffee, I may regret my stupidity in sending this out!
>>
>>
>>
>>
>>
>> --
>>
>> Katharine P. Bauer
>>
>> Bauer Pitman Lifetime Legal, PLLC
>> 1235 Fourth Ave. East, Suite 200
>> Olympia, Washington 98501
>> tel. 360.754.1976
>> fax. 360.943.4427
>>
>> e-mail: kpb at bpblegal.com
>>
>> This message is confidential and may be protected by the attorney-client
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>> If you are not the intended recipient, you are hereby advised that any
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>> Internal Revenue Code or (ii) promoting, marketing or recommending to
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>
>
>
> --
> Katharine P. Bauer
> Bauer Pitman Lifetime Legal, PLLC
> 1235 Fourth Ave. East, Suite 200
> Olympia, Washington 98501
> tel. 360.754.1976
> fax. 360.943.4427
>
> e-mail: kpb at bpblegal.com
>
> This message is confidential and may be protected by the attorney-client
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