This program provides a rigorous and practical analysis of the emerging application of Section 68 in the fiduciary income tax context and its potential to disrupt established assumptions underlying Subchapter J of the Internal Revenue Code. Participants will gain a detailed understanding of how the so-called “two-thirty-sevenths haircut” may reduce key fiduciary deductions, including distribution deductions under Sections 651 and 661 and charitable deductions under Section 642(c), creating unexpected phantom income and tax inefficiencies at the trust or estate level.

Earlier this year, we presented “Thirty-One Flavors of SLATs” — a webinar designed to illustrate the wide variety of options that should be considered when drafting Spousal Lifetime Access Trusts. In that presentation, we found far more than thirty-one ways to craft an irrevocable trust with the trust creator’s spouse as the primary beneficiary. We planned a follow-up drafting workshop to demonstrate a novel process — collaborative, AI-assisted, and built to deliver more value to the client. That workshop has arrived.