Information on the Grantor Statement will need to be reported on your annual federal income tax return. Beck as the liquidating trustee of the Crown Paper Liquidating Trust, in a series of adversary proceedings in the US Bankruptcy Court for the Northern District of California.The answer is, "It depends." The beneficiaries, and perhaps the trusts themselves, are subject to the income tax.It is important to recognize that this prudent and conservative estimate of zero value is solely for tax purposes and does not necessarily represent the future value of the trust units when and if such contingencies are resolved.IT IS IMPORTANT, THEREFORE, TO SEEK ADVICE OF A TAX PROFESSIONAL FAMILIAR WITH YOUR SPECIFIC TAX SITUATION.
Additionally, advisers should consider the grantor trust rules and how they may provide further options for income shifting.Here, the Court believes that the PBGC's policy is based upon a construction of the statute that is permissible, and indeed the more plausible. benefit liabilities," and merger is the legal equivalent of annuitization. §1001 , to consider a merger with a multiemployer plan as a method of terminating the plan.PACE argues that §1341(b)(3)(A)(ii)'s residual provision referring to an asset distribution that " fully provide[s] all benefit liabilities under the plan" covers merger because annuities (covered by §1341(b)(3)(A)(i)) are an example of a permissible means of "provid[ing] . Even assuming that PACE is right about the meaning of the word "otherwise," the clarity necessary to disregard the PBGC's considered views is lacking for three reasons. Crown Paper and its parent entity, Crown Vantage (the two hereinafter referred to in the singular as Crown), employed 2,600 persons in seven paper mills. In this case, Crown served as both plan sponsor and plan administrator.Crown did not breach its fiduciary obligations in failing to consider PACE's merger proposal because merger is not a permissible form of plan termination under ERISA. To decide that merger is also a permissible method, the Court would have to disagree with the Pension Benefit Guaranty Corporation (PBGC), the entity administering the federal insurance program that protects plan benefits, which takes the position that §1341(b)(3)(A) does to (rather than an example of) plan termination.The Court has traditionally deferred to the PBGC when interpreting ERISA.