Event Details
December 22, 2000
Description
The Tax Court decision in Walton v. Commissioner (115 T.C. No. 41) was issued, which allows a GRAT to be 'zeroed out'.
Participants (3)
| Name | Type | Mentions | |
|---|---|---|---|
| United States Tax Court | organization | 34 | View Entity |
| Commissioner | person | 9 | View Entity |
| Walton | person | 88 | View Entity |
Source Documents (1)
HOUSE_OVERSIGHT_022354.jpg
This confidential J.P. Morgan document from the HOUSE_OVERSIGHT files explains the "Cascading GRAT" financial strategy. The strategy involves a grantor transferring assets into a series of Grantor Retained Annuity Trusts (GRATs), using annuity payments from older GRATs to fund new ones, with the goal of passing wealth to beneficiaries free of gift tax. The document notes a 2012 gift tax exemption of $5,120,000 and cites the 2000 Walton v. Commissioner case that allows for a "zeroed out" GRAT to eliminate gift tax liability.
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