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Crummey Powers in Estate Planning


Understand how Crummey powers can be used to achieve your client's estate planning goals.

The decision in Crummey v. Commissioner directly addressed a fundamental flaw in tax policy - the inability for parents to make annual gift tax exclusion gifts to their children in trust. After Crummey, parent-donors had a procedure by which to make such exclusion gifts. Indirectly, the Crummey decision spawned the rise of Crummey powers in estate planning, affording taxpayers and their advisors the ability to reduce methodically their gross estates and avoid estate and gift tax consequences. This topic will assist estate planners in understanding the development and practical application of Crummey powers, giving them a powerful tool to assist clients with achieving their estate planning goals.



Todd Denison

Todd Denison

Phelps Dunbar LLP

  • Partner with Phelps Dunbar LLP
  • Represents individuals and business entities in the areas of business transactions and operations, partnership and corporate taxation, real and personal property transactions, trusts and estates (including sophisticated estate) planning, charitable organizations (formation and operations), employee stock ownership plans and other qualified retirement plans, captive insurance, international transactions and taxation, tax controversies with the IRS, and elder law
  • Clients include a regional engineering firm, national advertising agency, regional construction firm, regional stone and interior design firm, and numerous family-owned businesses operating locally, regionally, and internationally
  • Frequent speaker and has several publications
  • Member of numerous professional and civic organizations
  • Achieved the highest rating with Martindale-Hubbell Law Directory
  • The Best Lawyers in America¬© (Woodward/White, Inc.), Business Organizations (including LLCs and Partnerships) in Mobile, 2019; Tax Law in Mobile, 2018-2019; Trusts and Estates in Mobile, 2018-2019
  • LL.M. degree, New York University School of Law; J.D. degree, University of Montana School of Law; M.A. and B.A. degrees, University of Montana
  • Can be contacted at 251-441-8206 or [email protected]

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