The memo discusses whether an exchange of art for stock under a substitution clause in a defective grantor trust (IDGT) is subject to sales tax. It explores the concept of IDGTs, their treatment for federal tax purposes, and the potential application of the alter ego doctrine to exempt such transactions from NYS sales tax. The memo references various legal cases and advisory opinions to support the argument that an IDGT and its grantor could be considered alter egos, thus exempting the transaction from sales tax.
documents/EFTA01137470.pdf
{}