Wealth and Law is a project of attorney Brent Nelson and guests who share their knowledge in an educational, collaborative, and innovative format, with the goal of improving access to important information for professionals and individuals.
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Options to Avoid the Impact of Footnote 102
Brent chats about what options might be available to avoid the application of the JCT’s Blue Book’s footnote 102. He discusses the distribution mechanisms, beneficiary deemed owned trusts, qualified subchapter s trusts, non-trust options, and charitable remainder trusts. He also talks about the unknowns of how footnote 102 will actually apply.
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Footnote 102 to the Blue Book
Brent chats about footnote 102 to the Joint Committee on Taxation’s Blue Book explanations of OBBBA. He explains how the JCT applies the 2/37 limitation on itemized deductions to the income distribution deduction for nongrantor trusts and estate, what that could mean, and what is still unknown.
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