Wegbreit: a cautionary tale for trustees, lawyers and wealth owners. Issue 2 (22nd January 2020)

• Record Type: Journal Article
• Authors: Hunter, Chelsea; Gifford, James
• Is Part Of: Trusts & trustees. Volume 26:Issue 2(2020)
• Page Start: 195
• Page End: 198
• Publication Date: 2020-01-22
• Subjects: Trusts and trustees -- Periodicals; 346.05
• DOI: 10.1093/tandt/ttz131
• Languages: English
• ISSNs: 1363-1780

Abstract

Abstract: On 8 July 2019, the US Tax Court held that a grantor trust holding offshore life insurance constituted a sham. A review of the facts of the case and the court's opinion offer a cautionary tale to those planning, maintaining, or benefitting from similar wealth-holding structures. Like most cautionary tales, this one blends a unique factual milieu with tragic decision-making. But, unlike most cautionary tales, this one helps to illustrate some fundamental tax and wealth structure planning points.