HOUSE_OVERSIGHT_022355.jpg
1.59 MB
Extraction Summary
5
People
4
Organizations
0
Locations
2
Events
1
Relationships
4
Quotes
Document Information
Type:
Financial strategy document
File Size:
1.59 MB
Summary
This confidential J.P. Morgan document, page 5 of a set from a House Oversight collection, illustrates the 'Economic flows of Cascading GRATs,' a complex financial and estate planning strategy. It models a hypothetical 5-year scenario where a $50 million initial investment is moved through a series of Grantor Retained Annuity Trusts (GRATs) to transfer wealth from a 'grantor' to a 'beneficiary', with calculations based on a 2000 Tax Court ruling. The document is for illustrative purposes only and does not name specific individuals involved in a transaction.
People (5)
| Name | Role | Context |
|---|---|---|
| grantor | Asset Holder |
A generic term for the person funding the Grantor Retained Annuity Trust (GRAT). In this model, the grantor makes an ...
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| beneficiary | Trust Recipient |
A generic term for the person or entity who receives the remaining assets from the GRAT after the annuity payments to...
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| insiders | Corporate Insiders |
Mentioned in a disclaimer regarding securities laws issues that should be discussed with advisors.
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| Walton | Litigant |
Party in the Tax Court case 'Walton v. Commissioner', which is cited as the basis for the calculation.
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| Commissioner | Litigant (likely IRS) |
Party in the Tax Court case 'Walton v. Commissioner'.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| J.P. Morgan |
The creator of the document, as indicated by the logo at the bottom.
|
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| IRS (Internal Revenue Service) |
Mentioned in relation to the 'IRS discount rate' used in the GRAT calculations.
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| U.S. Tax Court |
Mentioned as the source of the 'Walton v. Commissioner' ruling, which the document's calculations are based on.
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| House Oversight |
Appears in the Bates number 'HOUSE_OVERSIGHT_022355', suggesting the document is part of evidence or records for a co...
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Timeline (2 events)
2000-12-22
A U.S. Tax Court ruling was issued in the case of Walton v. Commissioner (115 T.C. No. 41). The calculations in this document are based on this ruling.
A hypothetical 5-year financial strategy called 'Economic flows of Cascading GRATs' is detailed, showing the flow of funds from an initial $50 million investment between a grantor and a beneficiary.
Relationships (1)
The entire document describes a financial strategy where a grantor transfers assets to a series of trusts (GRATs) for the ultimate benefit of a beneficiary.
Key Quotes (4)
"Note: Assumes grantor survives all GRAT terms"Source
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Quote #1
"Note: Model does not include income taxes; the ongoing income taxes generated by the trust are paid by the grantor, income tax implications should be carefully considered"Source
HOUSE_OVERSIGHT_022355.jpg
Quote #2
"Numbers have been rounded for convenience, are only estimates for illustrative purposes and should not be relied upon."Source
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Quote #3
"Calculation is based on 2000 Tax Court ruling in Walton v. Commissioner (115 T.C. No. 41 (Dec. 22, 2000)."Source
HOUSE_OVERSIGHT_022355.jpg
Quote #4
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