Why The IRS Will Continue To Challenge Section 643(b) Trusts

Contributing sentiments towards policy:

52% : However, Subchapter J recognizes in certain instances that the burden of the tax should pass to others.
48% : Moreover, in certain situations, Subchapter J passes the burden of the tax -- rather commonsensically -- to the trust beneficiaries, particularly if the beneficiaries receive the income items as a distribution from the trust.
46% : Section 643(b) does not modify these general rules related to trust taxation.
41% : According to Aegis, entering into this trust arrangement alone resulted in significant tax savings.
40% : According to the promoters, these trust arrangements receive special tax benefits -- and hence, their name -- from section 643(b) of the Internal Revenue Code.

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