Blue Madeira Health Gluco Burn

USA, New York City, 10001

https://www.facebook.com/bluemadeirahealthglucoburn/

Blue Madeira Health Gluco Burn - The beneficiary will be a co-trustee of the trust (along with two independent co-trustees).The beneficiary will have the unilateral power to withdraw all contributions made to the trust. However, this power will lapse each calendar year in an amount equal to the greater of $5,000 or 5% of the value of the trust.The beneficiary will also have the power, during his lifetime, to direct the net income and/or principal of the trust to be paid over or applied for his health, education, maintenance and support (“HEMS”), and this power will not lapse.

The beneficiary will have a testamentary limited (non-general) power of appointment to “re-write” the disposition of the trust assets upon his death;

The trust provides that neither the grantor nor the grantor’s spouse may act as a trustee, and that no more than one-half of the trustees may be related or subordinate to the grantor within the meaning of IRC Section 672(c).

The trust contains various provisions assuring that the grantor will not be treated as the owner of the trust for income tax purposes under IRC Sections 671 – 679.

The IRS ruled that the trust did not contain any provisions that would cause the grantor to be considered the owner of the trust for income tax purposes. Instead, the IRS ruled that the beneficiary will be treated as the owner of the trust for income tax purposes – before and after the lapse of the beneficiary’s withdrawal rights. The IRS analysis was as follows.

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