This document reviews U.S. federal transfer tax aspects of a freeze structure under current law, based on a sample Agreement of Trust for a Delaware Statutory Trust. It discusses the structure of the Freeze Entity, the implications of Chapter 14 of the Internal Revenue Code, and the valuation and reporting requirements for preferred and residual units. The document also addresses the interaction of gift and income taxes, the timing of preferred payments, and the potential inclusion of Freeze Entity assets in the investor's estate under Section 2036.
documents/EFTA00742418.pdf
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