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:
“I believe that the highest virtue is to be happy, living in the greatest truth, not submitting to the falsehood of these personal times.”
—D.H. (David Herbert)
“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)
“Baseball is the religion that worships the obvious and gives thanks that things are exactly as they seem. Instead of celebrating mysteries, baseball rejoices in the absence of mysteries and trusts that, if we watch what is laid before our eyes, down to the last detail, we will cultivate the gift of seeing things as they really are.”
—Thomas Boswell, U.S. sports journalist. “The Church of Baseball,” Baseball: An Illustrated History, ed. Geoffrey C. Ward, Knopf (1994)