White Paper

4 Pages
  • 4 Pages

Hanging Crummey Powers

 

Review GST contributions and Crummey Powers.

A Hanging Crummey power allows the withdrawal right to lapse only for the amount that IRC § 2514(e) protects from treatment of release, which is the gift amount less the greater of $5,000 or 5% of the value of the property out of which the withdrawal right could have been satisfied. This white paper reviews this approach which is a popular and creative technique designed to circumvent the 5 and 5 limitation and enable a grantor to obtain the full annual exclusion from gift tax without creating adverse tax consequences for a beneficiary.