Federal Income Taxation of Trusts & Estates

Catalog description

In this course, we will explore the federal income taxation of trusts and estates, including constitutional matters and how current tax law has been influenced by non-tax rules governing the administration of trusts and estates. Those trust administration developments help explain, not only the function and evolution of related federal tax rules, but why IRS Forms 1041 that used to be titled “U.S. Fiduciary Income Tax Return” are today titled “U.S. Income Tax Return for Estates and Trusts.” The goal of the course is to provide students with both (i) a reasonable familiarity with the operation of U.S. fiduciary income tax law and (ii) a deeper understanding of related tax equity and policy themes, including through an examination of the original purposes of federal income tax “trust throwback” and “grantor trust” rules. While doing that, we'll hopefully have some good discussions about the differences, if any, between “planning opportunities” and “loopholes.”