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Full-Text Articles in Insurance Law
Taxation - Federal Gift Tax - Integration With Income Tax, Katherine Kempfer
Taxation - Federal Gift Tax - Integration With Income Tax, Katherine Kempfer
Michigan Law Review
Beck in 1935 created an irrevocable funded insurance trust of $172,000 in securities together with seven policies of insurance on his life. The income from the securities was to be applied to pay the premiums on the policies and any surplus was to be distributed to his wife and daughter. At grantor's death the proceeds of the policies were to be added to the corpus of the trust and all income was to go to the same beneficiaries for life with remainders over. There was no possibility of reverter in the grantor and no right to alter, modify or revoke …
Taxation -- Insurance And Annuity Contracts Under The Federal Estate Tax -- Differentiation And Theories Of Taxation, Charles F. Dugan
Taxation -- Insurance And Annuity Contracts Under The Federal Estate Tax -- Differentiation And Theories Of Taxation, Charles F. Dugan
Michigan Law Review
In the taxpayer's quest for methods of avoidance of the federal estate tax, one field seems to have been generally overlooked; viz., annuity contracts that are so similar to insurance policies as to be treated like the latter for tax purposes, thus securing the benefit of the $40,000 exemption in section 302 (g). Various reasons might be suggested why this should be so, but the fact remains that there has been practically no discussion of the subject in legal publications and, until the recent case of Old Colony Trust Co. v. Commissioner of Internal Revenue, no litigation involving the …