Personal Residence Trusts
To escape valuation under Code section 2702 (i.e., retained interest valued at zero), a PRT must comply with the following two primary requirements: (i) the trust may hold only one residence which must be used as the grantor’s personal residence during the term of the trust; and (ii) the trust may not allow the sale of the residence during the term of the trust. Additionally, following the expiration of the residence term, sale to grantor or grantor’s spouse is also prohibited.
The inability to sell the residence is a major restriction on the flexibility of a PRT and usually makes QPRTs more desirable. PRTs do not, however, have many other technical restrictions that QPRTs are subject to.
Read more about this topic: Qualified Personal Residence Trust
Famous quotes containing the words personal, residence and/or trusts:
“If any personal description of me is thought desirable, it may be said, I am, in height, six feet, four inches, nearly; lean in flesh, weighing, on an average, one hundred and eighty pounds; dark complexion, with course black hair, and grey eyes—no other marks or brands recollected.”
—Abraham Lincoln (1809–1865)
“My residence was more favorable, not only to thought, but to serious reading, than a university; and though I was beyond the range of the ordinary circulating library, I had more than ever come within the influence of those books which circulate round the world, whose sentences were first written on bark, and are now merely copied from time to time on to linen paper.”
—Henry David Thoreau (1817–1862)
“No married woman ever trusts her husband absolutely, nor does she ever act as if she did trust him. Her utmost confidence is as wary as an American pickpocket’s confidence that the policeman on the beat will stay bought.”
—H.L. (Henry Lewis)