In Focardi v. Commissioner,1 the Tax Court has once again shown a taxpayer the door in the case of a grantor retained annuity trust (GRAT) with a revocable annuity payable to the grantor and the grantor's spouse2 (a...
During the late 1990s, U.S. tax law became increasingly hostile to offshore trusts1 that benefit U.S. taxpayers. Tax compliance and planning became much more difficult for non-grantor trusts and new rules put more...
