The income taxation of trusts, estate, grantors, and beneficiaries (Subchapter J) is an odd backwater for estate planners because it is at once the tax that affects most estate plans, the one the government seems to ignore in the main, and (perhaps therefore) the one that we hardly ever teach or study. Fiduciary entities are subject to the highest income tax rates and enjoy the lowest exemptions, yet there are few "experts" among us and even less planning devoted to these realities. This session will focus first on the basics of Subchapter J and then delve a bit more into specifics of planning with intentionally defective grantor trusts, especially including the myths and hype surrounding them.  This is an intermediate/advanced program.

Jeffrey N. Pennell is the Richard H. Clark Professor of Law at Emory University School of Law in Atlanta. He is a member of the American Law Institute and an advisor for the Restatements of Wills and Other Donative Transfers, and of Trusts, a former member of the council of the Real Property, Trust Estate Section of the American Bar Association, an academic fellow and former regent of ACTEC, and an academician of The International Academy of Estate and Trust Law. His various publications include student and practitioner texts, tax management portfolios, articles, institute chapters, and he is the successor author of Casner Pennell on Estate Planning (6th ed.).

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