Perhaps no estate-planning tool is more subject to the law of unintended consequences than the ubiquitous Crummey1 power. But, although there can be estate, gift and generation-skipping transfer (GST) tax consequences, it's the income tax impact that is most often overlooked. In some cases, these surprises do not become apparent until later, perhaps when a question arises regarding a trust's qualification as a subchapter S shareholder.
Simply put, a Crummey power is a gener
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